Response as to Carla Jackson, John Gaines, Jerry Baptiste, Teldrin Foster — USA v. Thomas et al. (Dkt. 799, N.D. Ga.)

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 799 · 2024-01-05 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA 
v. 
TELDRIN FOSTER, 
JOHN GAINES A/K/A 
MARTY GAINES 
JERRY BAPTISTE, AND 
CARLA JACKSON 
Criminal Action No. 
1:20-CR-296-JPB-CMS-5, 11,  
   13, 20 
  
United States’ Response to Defendants’ Motions  
for Disclosure of Government Cooperating Witnesses’  
Sealed Plea Agreements and Presentence Investigation Reports 
The United States of America, by Ryan K. Buchanan, United States 
Attorney for the Northern District of Georgia, and Tal C. Chaiken and 
Samir Kaushal, Assistant United States Attorneys, and by Glenn S. Leon, 
Chief of the Fraud Section, and Siji Moore, Trial Attorney, respectfully files 
this response to the defendants’ Motions for Disclosure of Government 
Cooperating Witnesses’ Sealed Plea Agreements and Presentence 
Investigation Reports. (Docs. 779, 782, 783, 784.)  
1. The defendants have requested the disclosure of Presentence 
Investigation Reports (“PSRs”) and sealed plea agreements for co-
defendants who may testify at trial. (See Doc. 779 at 4.) 
2. On or about December 26, 2023, the United States filed under seal a 
motion seeking ex parte review of PSRs for co-defendants who may testify 
Case 1:20-cr-00296-JPB-CMS     Document 799     Filed 01/05/24     Page 1 of 3

2 
at trial. (Docs. 777, 778.) The motion attached as exhibits the PSRs in the 
United States’ possession and contained highlighting identifying the 
sections that the United States proposes should be disclosed to the defense. 
The motion also attached a proposed order authorizing the disclosure of 
the relevant portions of the PSRs. At the Court’s order, the United States 
will send the portions of the PSRs that the Court orders should be 
disclosed to the defendants via electronic mail. 
3. There are no under seal plea agreements in this case. All plea 
agreements are available on the public docket. In the United States’ 
possession, there is one under seal plea agreement addendum and one 
signed proffer letter from a case charged in another District that the United 
States would like to make available for defense counsels’ review at the U.S. 
Attorney’s Office. Defense counsel can contact the U.S. Attorney’s Office to 
schedule a time to conduct their review of these two documents. 
 
 
[This space intentionally left blank] 
 
 
Case 1:20-cr-00296-JPB-CMS     Document 799     Filed 01/05/24     Page 2 of 3

3 
 
Respectfully submitted, 
 
RYAN K. BUCHANAN 
United States Attorney 
GLENN S. LEON 
Chief, Fraud Section 
 U.S. Department of Justice 
 
/s/ Tal C. Chaiken 
TAL C. CHAIKEN 
Assistant United States Attorney 
Georgia Bar No. 273949 
 
/s/ Siji Moore 
SIJI MOORE 
Trial Attorney, Fraud Section 
 U.S. Department of Justice 
 
 
/s/ Samir Kaushal 
SAMIR KAUSHAL 
Assistant United States Attorney 
Georgia Bar No. 935285 
 
 
600 U.S. Courthouse 
75 Ted Turner Drive SW 
Atlanta, GA 30303 
404-581-6000; Fax: 404-581-6181 
 
1400 New York Ave, NW 
Bond Building, 11th Floor 
Washington, DC 20005 
202-514-2000; Fax: 202-514-3708 
 
Case 1:20-cr-00296-JPB-CMS     Document 799     Filed 01/05/24     Page 3 of 3

File and source

File

gov.uscourts.gand.279867.799.0.pdf

Size

124,446 bytes

SHA-256

e8c1313ab8bceea1542f9ef20008284136ee40cfef783428c5bc9666958e3fa1

Our copy

gov.uscourts.gand.279867.799.0.pdf

Original

PACER (login required)