Court filing
Motion for Protective Order by USA as to Charmaine Redding — USA v. Redding (Dkt. 6, N.D. Ga.)
Filed May 27, 2021 in Charmaine Redding; one of 12 filings from this case.
Record facts
| Court | U.S. District Court for the Northern District of Georgia |
|---|---|
| Filed | 2021-05-27 |
U.S. District Court for the Northern District of Georgia · No. 1:21-cr-00178-JPB · Doc. 6 · 2021-05-27 · Docket on CourtListener
Full text
FILED IN CHAMBERS J II I i.Jl I I ^ ^l I. Vi MAY 27 I i If U.S. MAGI'STRATE JUDGE N.D.GEORGIA IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DF^ISION UNITED STATES OF AMERICA V. CHARMAINE REDDING Case No. 1:21-CR-178 Government s Unopposed Motion for Protective Order for Discovery Materials The United States of America/ by Kurt R. Erskine/ Acting United States Attorney/ and Tal C. Chaiken and Nathan P. Kitchens, Assistant United States Attorneys 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 her defense/ pursuant to Federal Rule of Criminal Procedure 16(d)(l). In support of its motion/ the United States submits as follows: 1. On May 27,2021, the defendant waived indictment and was charged pursuant to a Criminal Information with one count of conspiracy to commit wire fraud in violation of Title 18, United States Code/ Section 1349. 2. The United States provided Rule 16 discovery to the defendant at arraignment 3. The United States considers many of the records that have been or may 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 Case 1:21-cr-00178-JPB Document 6 Filed 05/27/21 Page 1 of 5 individuals who 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)(l)/ 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)(l) ( [a]t any time the court may/ for good cause, deny, restrict, or defer discovery or inspection/ or grant other appropriate relief7). 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 her counsel to any individuals/ organizations/ or other entities, except to: a. Members of the defense team (co-counsel/ paralegals/ investigators/ Utigation support personnel/ the defendant/ and secretarial staff); 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 her counsel exclusively for the Case 1:21-cr-00178-JPB Document 6 Filed 05/27/21 Page 2 of 5 purpose of allowing the defendant to prepare a defense/ and that the defendant, defense counsel/ and 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. Pursuant to Local Criminal Rule 12.1 (D), undersigned counsel communicated with defense counsel about the relief sought m this motion. Undersigned counsel understands that the defendant consents to the entry of this protective order. WHEREFORE, and based on good cause shown/ the United States respectfully requests that the Court issue the submitted protective order. Case 1:21-cr-00178-JPB Document 6 Filed 05/27/21 Page 3 of 5 Dated: May 27,2021 Respectfully submitted/ KURT R. ERSKINE Acting United States Attorney /£. TAL C. CHAIKEN Assistant United States Attorney Georgia Bar No. 273949 Tal.Chaiken@usdoj.gov NATHAN p. KITCHENS Assistant United States Attorney Georgia Bar No. 263930 Nathan.Kitchens@usdoj .gov Case 1:21-cr-00178-JPB Document 6 Filed 05/27/21 Page 4 of 5 Certificate of Service The United States Attorney's Office served this document today by sending a copy by email to Sierra Lawrence/ attorney for Defendant Charmaine Redding. May 17, 2021 /S/ TAL C. CHAIKEN TAL C. CHAIKEN Assistant United States Attorney Case 1:21-cr-00178-JPB Document 6 Filed 05/27/21 Page 5 of 5
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