Court filing

Assented-To Motion for Alternative Discovery Schedule — United States v. Ebrahimzadeh

Summary

An assented-to motion for an alternative discovery schedule filed January 9, 2026 by the United States in United States of America v. David Ebrahimzadeh, Criminal No. 25-cr-10455-RGS, in the U.S. District Court for the District of Massachusetts (Document 27). Under Local Rule 116.1(e) and (f), the government asks that the initial production be due January 16, 2026 and automatic discovery be completed by February 20, 2026. It states that discovery is expected to involve over 1.3 million pages of documents and that vendor delays and the holidays prevent meeting the current deadline of January 9. The motion is signed by Assistant United States Attorney Elianna J. Nuzum and states that defense counsel assented.

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Filed January 9, 2026 in USA v. Ebrahimzadeh; one of 35 filings from this case.

Record facts

Court	U.S. District Court for the District of Massachusetts
Filed	2026-01-09

Cite this document

“Assented-To Motion for Alternative Discovery Schedule — United States v. Ebrahimzadeh.” U.S. District Court for the District of Massachusetts, No. 1:25-cr-10455-RGS, Doc. 27, filed 2026-01-09. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-david-ebrahimzadeh-mad-293123/2026-01-09-gov-uscourts-mad-293123-27-0-doc-27/, SHA-256 6d325afc4d1b2a4eb8605b1db32214633a8b61f256728ba737edf3edf914d626.

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Case 1:25-cr-10455-RGS Document 27 Filed 01/09/26 Page1of3

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA

Vv.
Criminal No. 25-cr-10455-RGS
DAVID EBRAHIMZADEH

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.
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,

Jan 9, 2026

(A David H. Hennessy |

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 27 Filed 01/09/26 Page3of3

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