United States v. Ngige, ___ F.3d ___ (1st Cir. Mar. 17, 2015) (the charge was filed within the five-year statute of limitations, since defendant's submission of a psychological evaluation in support of her Violence Against Women Act (VAWA) petition was properly considered an overt act in furtherance of the conspiracy charged; since the conspiracy's objective was to pay the co-conspirators to help defendant "acquire a change of her immigration status" by "making false representations about her marriage and relationship," the psychological evaluation sought to achieve that goal).

 

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