Consent Motion for Protective Order by USA as to Austin Martin Siampwizi — USA v. Siampwizi (Dkt. 21, N.D. Ga.)

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:23-cr-00246-WMR-RDC · Doc. 21 · 2023-08-17 · Docket on CourtListener

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IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA 
v. 
AUSTIN MARTIN SIAMPWIZI 
 
 
Criminal Action No. 
1:23-CR-246-WMR-RDC 
 
Government’s Consent Motion for Protective Order  
for Discovery Materials  
The United States of America, by Ryan K. Buchanan, United States Attorney, 
and Sarah E. Klapman, Assistant United States Attorney for the Northern District 
of Georgia, moves for a protective order to limit the defendant’s use and 
dissemination of information provided in discovery to that which is reasonably 
necessary to prepare his defense, pursuant to Federal Rule of Criminal Procedure 
16(d)(1).   
 In support of its motion, the United States submits as follows: 
1. On July 25, 2023, a federal grand jury sitting in the Northern District of 
Georgia returned a five-count Indictment against the defendant Siampwizi for: 
(1) one count of conspiracy to commit money laundering, in violation of 18 
U.S.C. § 1956(h); (2) three counts of concealment money laundering, in violation 
of 18 U.S.C. § 1956(a)(1)(B)(i); and (3) one count of wire fraud, in violation of 18 
U.S.C. § 1343. 
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2. The United States will provide Rule 16 discovery to the defendant as soon 
as possible. 
3. The United States considers many of the records that will be produced in 
this case to be “sensitive materials” in that they contain dates of birth, addresses, 
social security numbers, and bank account numbers for individuals that are not 
parties to this litigation. Given the volume of discovery materials in this case, 
redaction of all “sensitive information” within the materials would be unduly 
burdensome and would be subject to error.  Further, the degree of redaction that 
would be required for certain documents may obscure some of the documents 
and make them illegible.  
4. As a result, pursuant to Federal Rule of Criminal Procedure 16(d)(1), the 
United States requests that a protective order be issued to guard against the 
unwarranted dissemination of the discovery materials in this case. See FED. R. 
CRIM. P. 16(d)(1) (“[a]t any time the court may, for good cause, deny, restrict, or 
defer discovery or inspection, or grant other appropriate relief”). 
5. First, the United States requests an order mandating that any discovery 
materials and all information included in the discovery materials (regardless of 
whether such materials are defined as discovery under Rule 16) that are 
provided by the United States to the defendant, shall not be further disseminated 
by the defendant or his counsel to any individuals, organizations, or other 
entities, except than to: 
a. Members of the defense team (co-counsel, paralegals, investigators, 
litigation support personnel, the defendant, and secretarial staff); 
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b. Any experts or consultants retained to assist in the preparation of the 
defense; or 
c. The Court. 
6. Second, the United States requests an order requiring that all discovery is 
to be provided and used by the defendant and his counsel exclusively for the 
purpose of allowing the defendant to prepare a defense, and that the defendant, 
defense counsel, or members of the defense team will not disseminate, disclose, 
or provide the discovery produced by the United States to anyone who is not 
necessary to the preparation of the defense. 
7. The United States submits that these protective measures are necessary to 
guard against dissemination of confidential and sensitive personal information 
and that a protective order is the most reasonable way of balancing the 
defendant’s need for access to these materials with the rights of individuals 
whose information may be reflected in this discovery. 
8. Defendant consents to the entry of the attached protective order. 
 
 
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WHEREFORE, and based on good cause shown, the United States 
respectfully requests that the Court issue the submitted protective order. 
Dated:   August 17, 2023 
Respectfully submitted, 
RYAN K. BUCHANAN 
United States Attorney 
/s/SARAH E. KLAPMAN 
Assistant United States Attorney 
Georgia Bar No. 437221 
sarah.klapman@usdoj.gov 
 
 
 
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Certificate of Service 
The United States Attorney’s Office served this document today by filing it using 
the Court’s CM/ECF system, which automatically notifies the parties and counsel 
of record. 
Lynsey Barron 
Counsel for Defendant Siampwizi 
August 17, 2023 
 
/s/ SARAH E. KLAPMAN 
 
 
SARAH E. KLAPMAN 
 
Assistant United States Attorney 
 
 
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