Unopposed MOTION for Protective Order as to Early Discovery by USA as to… — USA v. Denton - Cindi Ellis Denton (Dkt. 14)

Summary

Document 14, a four-page Government's Unopposed Motion for a Protective Order Regulating Disclosure of Limited Discovery, filed 05/13/2021 in the Southern District of Florida, United States v. Cindi Ellis Denton. The government wants to give defense counsel limited discovery before the arraignment set for June 21, 2021, and says it includes personal identification information and bank account information. It proposes that this material be marked Confidential, shown to the client, staff, investigators and witnesses only as needed, with a signed certification from each outside recipient, and destroyed or returned to the United States at the end of the case. A footnote cites COVID-19 administrative orders that continued trials and limited grand jury sessions. The defense does not oppose, and Assistant U.S. Attorney Lindsey Lazopoulos Friedman signs for the government.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.  21-6149-MJ-HUNT 
 
UNITED STATES OF AMERICA  
  
 
 
 
 
 
vs. 
 
 
 
 
  
   
 
 
 
CINDI ELLIS DENTON, 
 
          Defendant. 
________________________________________/ 
 
GOVERNMENT’S UNOPPOSED MOTION FOR A PROTECTIVE ORDER  
REGULATING DISCLOSURE OF LIMITED DISCOVERY  
AND SENSITIVE INFORMATION CONTAINED THEREIN 
 
 
The United States of America files this unopposed motion for a protective order regulating 
disclosure of limited discovery materials in this case and certain sensitive information contained 
therein (“Limited Discovery”). The government seeks to disclose Limited Discovery to counsel 
for the defendant, Cindi Ellis Denton, prior to the arraignment, which is currently scheduled for 
June 21, 2021. (DE 11).1 
 
 The Complaint in this case charges wire fraud, bank fraud, and conspiracy and attempt to 
commit wire fraud and bank fraud. The Limited Discovery includes, among other things, 
documents containing personal identification information (“PII”) (e.g., names, dates of birth, and 
 
1In response to the global COVID-19 pandemic, the Chief Judge for the Southern District of 
Florida has entered several administrative orders continuing jury trials and trial deadlines, and 
restricting grand jury presentations in the District.  Specifically, on April 6, 2021, the most recent 
order, Administrate Order 2021-33 (“AO 2021-33”), continued jury trials and all trial-specific 
deadlines in criminal cases scheduled to begin before July 6, 2021. AO 2020-33 ¶ 6, 7. AO 2020-
33 further restricted grand jury sessions for the Southern District of Florida to two per week, as 
opposed to the pre-pandemic norm of eleven sessions per week. AO 2020-33 ¶¶ 14, 15. AO 2020-
33 also excluded the period from March 26, 2020, through July 6, 2021, for purposes of the Speedy 
Trial Act requirement that an information or indictment charging an individual with the 
commission of an offense be filed within 30 days from the date on which such individual was 
arrested.  See also Administrative Order 2021-12; Administrative Order 2020-76; Administrative 
Order 2020-53; 2020-41; Administrative Order 2020-24; Administrative Order 2020-21; and 
Administrative Order 2020-18.  
 
Case 0:21-cr-60171-RS   Document 14   Entered on FLSD Docket 05/13/2021   Page 1 of 4

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social security numbers), bank account information, and other sensitive information (collectively, 
the “Sensitive Information”). The Sensitive Information in this case is an essential component of 
the crimes alleged in the Complaint. Therefore, counsel for the defendant will need to review the 
specific Sensitive Information to fully understand the allegations. Accordingly, to ensure the 
protection of the Sensitive Information and to avoid the disclosure of this information to other 
individuals, the government requests that the Court enter an order regulating disclosure of the 
Limited Discovery as follows:  
1. 
The government is authorized to disclose Sensitive Information in its possession 
that the government believes will help counsel understand the allegations in the Complaint, prior 
to the entry to the Standing Discovery Order;  
2. 
The government shall produce the Limited Discovery as follows. The Government 
shall mark that portion of the Discovery that includes Sensitive Information as “Confidential,” 
which will be governed by the following rules.   
3. 
With respect to the Confidential portion of the Limited Discovery, the following 
rules shall apply:  
a. 
Counsel of record for the defendant in this proceeding shall hold the 
Confidential portion of the Limited Discovery in strictest confidence.  Therefore, defense counsel 
shall restrict access to this discovery, and shall disclose this discovery to their client, office staff, 
investigators, and to anticipated fact or expert witnesses only to the extent that defense counsel 
believes is necessary to assist in the defense of their client in this matter and in a manner that will 
prohibit the disclosure of this discovery to other persons not involved in the defense;   
b. 
Counsel of record for the defendant shall advise any person to whom the 
Confidential portion of the Limited Discovery is disclosed that such information shall be held in 
Case 0:21-cr-60171-RS   Document 14   Entered on FLSD Docket 05/13/2021   Page 2 of 4

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strict confidence, and that further disclosure or dissemination is prohibited without defense 
counsel’s express consent; and  
c. 
Counsel of record for the defendant shall obtain a certification from each 
person to whom the Confidential portion of the Limited Discovery is disclosed, excluding 
members of the attorney’s office staff, in which the recipient, (a) acknowledges these restrictions 
as set forth in the Protective Order of the Court, and (b) agrees that they will not disclose or 
disseminate the information without express consent of defense counsel.  Counsel shall keep a 
copy of each certification to identify the individuals who received the Confidential portion of the 
Limited Discovery and the date on which such information was first disclosed.  
d. 
Counsel of record agrees that, upon conclusion of the above captioned case, 
copies of the Limited Confidential portion of the Discovery disclosed to defense counsel pursuant 
to the terms of this order shall be destroyed or returned to the United States.   
 
Counsel for the defendant does not oppose the relief requested herein.  
 
 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
JUAN ANTONIO GONZALEZ 
 
 
 
 
 
 
 
ACTING UNITED STATES ATTORNEY 
 
By: 
/s/ Lindsey Lazopoulos Friedman 
                                 
Lindsey Lazopoulos Friedman 
Assistant United States Attorney 
Florida Bar No. 091792 
99 NE 4th Street 
Miami, Florida 33132-2111 
Phone: (305) 961-9168 
Email: Lindsey.Friedman@usdoj.gov 
 
Case 0:21-cr-60171-RS   Document 14   Entered on FLSD Docket 05/13/2021   Page 3 of 4

 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on May 13, 2021, I electronically filed the foregoing 
document with the Clerk of the Court using CM/ECF. 
 
/s/ Lindsey Lazopoulos Friedman 
 
                
Lindsey Lazopoulos Friedman 
Assistant United States Attorney 
 
 
 
 
 
Case 0:21-cr-60171-RS   Document 14   Entered on FLSD Docket 05/13/2021   Page 4 of 4

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