Consent Motion for Entry of a Stipulated Protective Order by USA as to Craig David Davis — USA v. Davis (Dkt. 15, E.D. Va.)

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Consent Motion for Entry of a Stipulated Protective Order, Document 15, filed 03/07/24 in Case 1:24-cr-00040-PTG, United States of America v. Craig David Davis, Eastern District of Virginia. The United States moves under Federal Rule of Criminal Procedure 16(d)(1) and Federal Rule of Evidence 502(d), stating that counsel for the defendant has reviewed the proposed order and does not oppose. The motion says the investigation produced voluminous documents, including bank records, law enforcement investigative reports and information from a cooperating source, that contain confidential information and personal identifiers. The proposed order would prohibit disseminating those records to third parties other than as necessary for the defendant's investigation and defense preparation. It is signed /s/ Kathleen E. Robeson, Assistant United States Attorney.

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IN THE UNITED STATES DISTRICT COURT Fd
EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES OF AMERICA
V.
CRAIG DAVID DAVIS,
Defendant.
r> 'rotr 
FILED
R THE tN OPEN COURT
MAR - T 2024
CLERK. U.S. DISTRICT COURT
ALEXANDRIA. VIRGINIA
Case No. l:24-CR-40 (PTG)
CONSENT MOTION FOR ENTRY OF A STIPULATED PROTECTIVE ORDER
The United States of America, by and through undersigned counsel, respectfully moves
this Honorable Court for entry of the attached stipulated Protective Order, pursuant to Federal Rule
of Criminal Procedure 16(d)(1) and Federal Rule of Evidence 502(d). Counsel for the defendant
has reviewed the proposed protective order and advised that the defendant does not oppose this
Motion. In support thereof, the United States submits the following:
1. 
During the course of the investigation, the United States has gathered or generated
voluminous documents, including electronic records, which contain confidential information and
personal identifiers for the defendants, unindicted co-conspirators, and non-parties in this case.
These documents and electronic records currently include and are anticipated to include, but are
not limited to, bank records, law enforcement investigative reports, information from a cooperating
source, and other materials. The United States intends to produce these documents and electronic
records, in accordance with the Federal Rules of Criminal Procedure, relevant case law, and any
Discovery Orders that are agreed upon and entered in this case.
2. 
Accordingly, the proposed Protective Order regulates discovery in this case by
restricting the use and dissemination of documents and electronic records obtained through
Case 1:24-cr-00040-PTG     Document 15     Filed 03/07/24     Page 1 of 3 PageID# 68

discovery. In sum, the proposed Protective Order prohibits the dissemination of these documents
and electronic records and the information contained therein to third parties, other than as
necessary for the defendant's investigation of the allegations and preparation of his defense.
3. 
Counsel for the defendant has reviewed this motion and the proposed Protective
Order and has consented to its terms.
WHEREFORE, the undersigned respectfully requests that the Court enter the proposed
Protective Order.
Respectfully Submitted,
Jessica D. Aber
United States Attorney
By: 
/s/
Kathleen E. Robeson
Assistant United States Attorney
David A. Peters
Trial Attorney, Fraud Section
Counsel for the United States
Case 1:24-cr-00040-PTG     Document 15     Filed 03/07/24     Page 2 of 3 PageID# 69

CERTIFICATE OF SERVICE
Thereby certify that on March 7th, 2024, I electronically filed the foregoing using the
CM/ECF system, which will automatically send a notification of such filing to all counsel of
record.
/s/
Kathleen E. Robeson
Assistant United States Attorney
United States Attorney's Office
2100 Jamieson Avenue
Alexandria, Virginia 22314
Phone: 703-299-3700
Fax: 703-299-3982
Email: Kathleen.robeson@usdoj.gov
Case 1:24-cr-00040-PTG     Document 15     Filed 03/07/24     Page 3 of 3 PageID# 70

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