Assented to Motion for Extension of Time to 02/20/2026 — USA v. Ebrahimzadeh (Dkt. 26, D. Mass.)

Summary

In United States of America v. David Ebrahimzadeh, Criminal No. 25-cr-10455-RGS, the United States files an Assented-To Motion for Alternative Discovery Schedule. It asks that an initial production be due Friday, January 16, 2026 and that automatic discovery be completed by Friday, February 20, 2026. The motion states that automatic discovery is expected to involve the production of over 1.3 million pages of documents and that delays with its vendor and the holidays prevent completion by the current deadline of January 9. It states that the government anticipates seeking a protective order and that counsel for the defendant has assented, and it is signed by Assistant United States Attorney Elianna J. Nuzum on January 9, 2026.

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UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 
_______________________________________ 
 
 
UNITED STATES OF AMERICA 
 
 
 
v. 
 
DAVID EBRAHIMZADEH 
 
 
Criminal No. 25-cr-10455-RGS 
 
ASSENTED-TO MOTION FOR ALTERNATIVE DISCOVERY SCHEDULE 
 
Pursuant to Local Rule 116.1(e) and (f), the United States of America, with the assent of 
the defendant, requests that the Court adopt an alternative automatic discovery schedule, under 
which an initial production is due Friday, January 16, 2026, and automatic discovery is completed 
by Friday, February 20, 2026.   
 Automatic discovery in this matter is expected to involve the production of over 1.3 
million pages of documents.  The government began preparation of this production well before the 
defendant was charged and is on track to produce the initial 1.3 million pages of documents within 
the next week, but, due to delays with its vendor and the holidays, does not anticipate being able 
to complete this process by the current deadline of January 9.  Accordingly, the government 
requests until January 16, 2026 to make its initial, very substantial production, which will include 
an index.  The government anticipates seeking a protective order prior to this date as well. 
The government anticipates making at least one supplemental production thereafter to 
complete automatic discovery, and expects needing approximately one month to do so.  
Accordingly, the government requests until February 20, 2026 to complete automatic discovery.  
Should additional modifications be needed, the government will promptly alert the defense and 
the Court. 
Case 1:25-cr-10455-RGS     Document 26     Filed 01/09/26     Page 1 of 3

 
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WHEREFORE, the government requests that the Court adopt an alternative automatic 
discovery schedule, under which an initial production is due January 16, 2026 and automatic 
discovery is completed by February 20, 2026.  Counsel for the defendant has assented to this 
motion. 
 
Respectfully submitted, 
 
UNITED STATES OF AMERICA 
By its attorney, 
 
LEAH B. FOLEY 
United States Attorney 
 
/s/ Elianna J. Nuzum  
 
 
Elianna J. Nuzum  
Assistant United States Attorney 
John Joseph Moakley U.S. Courthouse 
One Courthouse Way, Suite 9200 
Boston, MA 02210 
elianna.nuzum@usdoj.gov 
617.748.3100 
 
Dated: January 9, 2026 
 
LOCAL RULE 7.1(A)(2) CERTIFICATION 
I hereby certify that, consistent with Local Rule 7.1(a)(2), the parties have conferred and 
attempted in good faith to resolve or narrow the issues presented in this motion, and the 
defendant, through counsel, has assented to this motion. 
/s/ Elianna J. Nuzum  
 
 
Elianna J. Nuzum  
 
 
 
Case 1:25-cr-10455-RGS     Document 26     Filed 01/09/26     Page 2 of 3

 
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CERTIFICATE OF SERVICE 
 
Undersigned counsel certifies that this document filed through the ECF system will be 
sent electronically to the registered participants as identified on the Notice of Electronic Filing 
(NEF) and paper copies will be sent to those indicated as non-registered participants.  
 
 
 
 
 
 
 
 
 
/s/ Elianna J. Nuzum  
 
 
 
 
 
 
 
 
 
Elianna J. Nuzum 
 
 
 
 
 
 
Assistant United States Attorney 
 
Dated: January 9, 2026 
Case 1:25-cr-10455-RGS     Document 26     Filed 01/09/26     Page 3 of 3

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