Motion by USA for protective order as to Te Dora Brown — USA v. Brown, et al. (Dkt. 25, N.D. Ill.)

Record facts

U.S. District Court for the Northern District of Illinois · No. 1:23-cr-00097 · Doc. 25 · 2023-03-09 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF ILLINOIS 
EASTERN DIVISION 
 
UNITED STATES OF AMERICA 
 
v. 
 
TE DORA BROWN, and 
CHRISTOPHER SCOTT 
 
No. 23 CR 97 
 
Judge Elaine E. Bucklo  
 
 
UNOPPOSED MOTION FOR PROTECTIVE ORDER 
GOVERNING DISCOVERY 
 Pursuant to Fed. R. Crim. P. 16(d) and 18 U.S.C. § 3771(a), the United States of 
America, by JOHN R. LAUSCH, JR., United States Attorney for the Northern District of 
Illinois, moves for the entry of a protective order, and in support thereof states as follows:     
1. 
The indictment in this case charges defendants with wire fraud, in 
violation of 18 U.S.C. § 1343.  
2. 
The discovery material to be provided by the government in this case 
includes particularly sensitive information, including information that discloses the 
identity of other witnesses, subjects, and targets of this ongoing investigation into 
bank fraud, bank bribery, wire fraud, and money laundering, among other offenses. 
Accordingly, the unrestricted dissemination of this information could adversely affect 
law enforcement interests and the privacy interests of third parties. 
3. 
The government has discussed the proposed protective order with 
defense counsel, who do not oppose the entry of the proposed protective order. 
Case: 1:23-cr-00097 Document #: 25 Filed: 03/09/23 Page 1 of 2 PageID #:107

 
 
2 
WHEREFORE the government respectfully moves this Court to enter the 
proposed protective order. 
 
Respectfully submitted, 
 
JOHN R. LAUSCH, JR.  
United States Attorney 
 
 
By: 
     /s/ Alejandro G. Ortega                  
ALEJANDRO G. ORTEGA 
Assistant United States Attorney 
219 S. Dearborn St., Rm. 500 
Chicago, IL  60604 
(312) 353-4129 
Case: 1:23-cr-00097 Document #: 25 Filed: 03/09/23 Page 2 of 2 PageID #:108

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