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

Summary

The United States' Response to Defendants' Motions for Disclosure of Government Cooperating Witnesses' Sealed Plea Agreements and Presentence Investigation Reports, Document 799, filed 01/05/24 in the Northern District of Georgia, Criminal Action No. 1:20-CR-296-JPB-CMS-5, 11, 13, 20, against Teldrin Foster, John Gaines, Jerry Baptiste and Carla Jackson. The government says it filed under seal on December 26, 2023 an ex parte motion for review of the presentence reports of co-defendants who may testify, and it will send the portions the Court orders disclosed by email. It says there are no under seal plea agreements, that all plea agreements are on the public docket, and that it holds one sealed plea agreement addendum and one signed proffer letter from a case in another District. It offers defense counsel a review of those two documents at the U.S. Attorney's Office.

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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

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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

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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

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