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Home Court filings USA v. Bella — Amos Mundendi filings, U.S. District Court, S.D.N.Y. PROTECTIVE ORDER as to Apocalypse Bella, Mackenzy Toussaint, Amos Mundendi...regarding……

Court filing

PROTECTIVE ORDER as to Apocalypse Bella, Mackenzy Toussaint, Amos Mundendi...regarding… — USA v. BELLA (Dkt. 34)

Record facts

CourtU.S. District Court for the Southern District of New York
Filed2021-06-21

U.S. District Court for the Southern District of New York · No. 1:21-cr-00247-PAE · Doc. 34 · 2021-06-21 · Docket on CourtListener

Summary

A protective order filed June 21, 2021 as Doc. 34 in United States v. Apocalypse Bella, Mackenzy Toussaint and Amos Mundendi, No. 1:21-cr-00247-PAE, in the U.S. District Court for the Southern District of New York, before District Judge Paul A. Engelmayer. It governs government discovery that contains personal identifying information of other individuals, citing Rule 16(d)(1) and Title 18, United States Code, Section 3771. Protected Material may be used only for this action, kept by the defendants or their counsel, shared only with defense staff, retained experts or persons the Court authorizes, and returned or destroyed at the end of the case. Sensitive Protected Material may be shown to the defendants but not kept in their possession. The order carries signature lines for AUSA Dina McLeod and defense counsel Charles Kaser, Bret Martin and Tamara Giwa.

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Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
- - - - - - - - - - - - - - - - x
  : 
UNITED STATES OF AMERICA 
  : 
: 
- v. -
  : 
  : 
PROTECTIVE ORDER 
21&5347 (PAE) 
APOCALYPSE BELLA, 
  : 
   a/k/a “Dias Yumba,” 
  : 
  : 
MACKENZY TOUSSAINT, 
  : 
   a/k/a “Mack,” and
: 
  : 
AMOS MUNDENDI, 
  : 
   a/k/a “Mos,”  
  :
   a/k/a “El Ashile Mundi,”     : 
  : 
Defendants. 
 : 
  : 
- - - - - - - - - - - - - - - - x
HONORABLE PAUL A. ENGELMAYER, District Judge:
WHEREAS the Government intends to produce to APOCALYPSE 
BELLA, MACKENZY TOUSSAINT, and AMOS MUNDENDI, the defendants, in 
the above-captioned matter, certain discovery materials that 
contain personal identifying information for individuals other 
than the defendant, including names, financial information, and 
telephone numbers; and  
WHEREAS pursuant to Rule 16(d) (1) and Title 18, United 
States Code, Section 3771, the Government desires to protect the 
confidentiality of the above-referenced materials, and for good 
cause shown; 
 
IT IS HEREBY ORDERED:  
Case 1:21-cr-00247-PAE     Document 34     Filed 06/21/21     Page 1 of 8

2 
1. Discovery materials produced by the Government to
the defendants or their counsel that are either (1) designated 
in whole or in part as "Subject to Protective Order” by the 
Government in emails or communications to defense counsel, or 
(2) that include a Bates or other label stating "Subject to
Protective Order," shall be deemed "Protected Material.”
2. Protected Material disclosed to the defendants, or
to their counsel, during the course of proceedings in this 
action: 
(a) shall be used by the defendants or their
counsel only for purposes of this action; 
(b) shall be kept in the sole possession of the
defendants’ counsel or the defendants; 
(c) shall not be copied or otherwise recorded by
the defendants; 
(d) shall not be disclosed in any form by the
defendants or their counsel except as set forth in 
paragraph 2(e) below; 
(e) may be disclosed only by the defendants’
counsel and only to the following persons (hereinafter 
"Designated Persons"): 
Case 1:21-cr-00247-PAE     Document 34     Filed 06/21/21     Page 2 of 8

3 
 
(i) secretarial, clerical, paralegal, 
investigative, and student personnel employed full-time or part-
time by the defendants’ counsel; 
(ii) independent expert witnesses retained 
by the defendants or on their behalf in connection with this 
action; and  
(iii) such other persons as hereafter may be 
authorized by the Court upon a motion by the defendants; 
(f) shall be either (i) returned to the 
Government following the conclusion of this case, together with 
any and all copies thereof, or (ii) destroyed together with any 
and all copies thereof, with defendants’ counsel verifying in 
writing to the Government that such destruction has taken place. 
(g) Notwithstanding the foregoing, the defense 
shall not be required to return or destroy any Protected 
Material to the extent such return or destruction would conflict 
with any applicable professional or ethical obligation or 
responsibility of the defense. 
3. Discovery materials produced by the Government to 
the defendants or their counsel that are either (1) designated 
in whole or in part as "Sensitive – Subjective to Protective 
Order" by the Government in emails or communications to defense 
counsel, or (2) that include a Bates or other label stating 
Case 1:21-cr-00247-PAE     Document 34     Filed 06/21/21     Page 3 of 8

4 
 
"Sensitive – Subjective to Protective Order" shall be deemed 
"Sensitive Protected Material.” 
4. Sensitive Protected Material disclosed to the 
defendants, or to the defendants’ counsel, during the course of 
proceedings in this action, shall be subject to the conditions 
applicable to Protected Material, with the exception of 
paragraph 2(b) above.  Sensitive Protected Material may be shown 
to the defendants, but may not be maintained in the defendants’ 
possession.  
5. 
The defendants and their counsel shall provide a 
copy of this Order to Designated Persons to whom Protected 
Material is disclosed pursuant to paragraph 2(e).  Designated 
Persons shall be subject to the terms of this Order. 
7. 
The provisions of this Order shall not be 
construed as preventing the disclosure of any information in any 
motion, hearing, trial, or sentencing proceeding held in this 
action, or to any judge or magistrate of this Court for purposes 
of this action. 
 
 
 
 
[intentionally left blank] 
Case 1:21-cr-00247-PAE     Document 34     Filed 06/21/21     Page 4 of 8

5 
 
 
 
Case 1:21-cr-00247-PAE     Document 34     Filed 06/21/21     Page 5 of 8

6 
 
8.  This Order may be signed in counterparts and 
transmitted by facsimile and/or electronic copy, each of which 
counterparts will be deemed to be an original and which taken 
together will constitute the Order. 
AGREED AND CONSENTED TO: 
AUDREY STRAUSS 
UNITED STATES ATTORNEY 
 
 
 
 
 
By:    
_____________________________________ 
Dina McLeod 
Assistant United States Attorney 
_____________________________________ 
Charles Kaser, Esq. 
Counsel for Apocalypse Bella 
_____________________________________ 
Bret Martin, Esq. 
Counsel for Mackenzy Toussaint 
_____________________________________ 
Tamara Giwa, Esq. 
Counsel for Amos Mundendi 
SO ORDERED: 
                           
_____________________________ 
                
HONORABLE PAUL A. ENGELMAYER 
                             UNITED STATES DISTRICT JUDGE 
________
Gi
E
Case 1:21-cr-00247-PAE     Document 34     Filed 06/21/21     Page 6 of 8

6 
 
8.  This Order may be signed in counterparts and 
transmitted by facsimile and/or electronic copy, each of which 
counterparts will be deemed to be an original and which taken 
together will constitute the Order. 
AGREED AND CONSENTED TO: 
AUDREY STRAUSS 
UNITED STATES ATTORNEY 
By:    
_____________________________________ 
Dina McLeod 
Assistant United States Attorney 
_____________________________________ 
Charles Kaser, Esq. 
Counsel for Apocalypse Bella 
_____________________________________ 
Bret Martin, Esq. 
Counsel for Mackenzy Toussaint 
_____________________________________ 
Tamara Giwa, Esq. 
Counsel for Amos Mundendi 
SO ORDERED: 
 
_____________________________ 
 
HONORABLE PAUL A. ENGELMAYER 
 
  UNITED STATES DISTRICT JUDGE 
/s/ Charles Kaser
Case 1:21-cr-00247-PAE     Document 34     Filed 06/21/21     Page 7 of 8

6/21/2021

Case 1:21-cr-00247-PAE     Document 34     Filed 06/21/21     Page 8 of 8

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