United States v. Foote O'Donoghue

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, v. RICHARD GRAHAM FOOTE Criminal Action No. 24-566 (CKK) O’DONOGHUE, Defendant. MEMORANDUM OPINION (July 22, 2026) Defendant Graham O’Donoghue moves to dismiss Counts One through Eight of the Indictment for lack of venue. These Counts charge O’Donoghue with tax evasion for the years 2012 through 2015 (Counts One through Four) and subscribing to false tax returns for those same years (Counts Five through Eight). O’Donoghue argues that neither the “high seas” venue statute, 18 U.S.C. § 3238, nor the general…