Status Report (Joint Initial Status Report and Request to Cancel Hearing) — USA v. Ebrahimzadeh (Dkt. 29, D. Mass.)

Summary

Document 29, a three-page Joint Initial Status Report and Request to Cancel Hearing filed 01/15/26 in the District of Massachusetts, Criminal No. 25-cr-10455-RGS, United States v. David Ebrahimzadeh. The parties ask to cancel the January 23, 2026 status conference and set an interim one in about 75 days, with time excluded. The government expects a first production on January 16, 2026 of over 2.1 million bates labeled pages or files in a database and over 14,000 outside it, and to finish automatic discovery by February 20, 2026. The defense says it is too early to decide on discovery requests or Rule 12(b) motions, and expert disclosures are set at 21 days before trial for the government and 14 for the defense. The report is signed by Scott Seitz for Ebrahimzadeh and Assistant U.S. Attorney Elianna J. Nuzum.

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Full text

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UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 
_______________________________________ 
 
 
UNITED STATES OF AMERICA 
 
 
 
v. 
 
DAVID EBRAHIMZADEH 
 
 
Criminal No. 25-cr-10455-RGS 
 
JOINT INITIAL STATUS REPORT AND REQUEST TO CANCEL HEARING 
 
 
Pursuant to Local Rule 116.5(a), the parties hereby file the following status report prepared 
in connection with the status conference on this matter scheduled for January 23, 2026, request 
that the status conference be cancelled, and request that an interim status conference be scheduled 
in approximately 75 days and that the time be excluded until that date. 
(1)        Automatic Discovery/Pending Discovery Requests 
 
Per the agreement of the parties and the alternative discovery schedule adopted by this 
Court (Dkt. No. 27), on January 16, 2026, or as soon thereafter as the proposed protective 
order is adopted, the Government expects to provide a first production of automatic 
discovery, consisting of the bulk of automatic discovery materials currently available, 
including over 2.1 million bates labeled pages and/or electronic files within an electronic 
database and over 14,000 bates labeled pages or files outside of the database.   
 
(2)        Additional Discovery 
 
The government is in the process of completing its review and preparation of materials 
for production, and anticipates making a supplemental production and completing 
automatic discovery on or before February 20, 2026.   
 
(3)        Timing of Additional Discovery Requests  
 
The defendant will need time to review the discovery being produced on January 16 and 
on February 20.  As such, he does not yet know whether or when he will make additional 
discovery requests and will assess this when automatic discovery is complete.  
 
 
 
Case 1:25-cr-10455-RGS     Document 29     Filed 01/15/26     Page 1 of 3

2 
 
(4)        Protective Orders 
 
The government has filed an assented-to motion for a discovery protective order, Dkt. 
No. 28, which is currently pending before the Court.   
 
(5)        Pretrial Motions 
 
Due to the fact that review of the discovery has not yet begun, it is premature for the 
defendant to decide whether to file any motions under Fed. R. Crim. P. 12(b).  The 
defendant will provide an update in connection with the next status conference. 
 
(6)        Expert Discovery 
 
The government agrees to provide any expert witness disclosures 21 days prior to trial. 
Defendant agrees to provide any expert witness disclosure 14 days prior to trial. 
 
(7)        Speedy Trial Act 
 
All of the time has been excluded from the date of defendant’s arraignment on December 
12, 2025, through the date of the initial status conference scheduled for January 23, 
2026.  See Dkt. Nos. 10, 23. The parties request that the time be excluded until the next 
status conference. The parties agree that this period constitutes “the reasonable time 
necessary for effective preparation, taking into account the exercise of due diligence,” and 
that the ends of justice served by granting the requested continuance outweigh the best 
interests of the public and the defendant in a speedy trial pursuant to the Speedy Trial Act, 
18 U.S.C. § 3161(h)(7)(A).   
 
(8)        Next Status Conference 
 
Given all of the foregoing information, the parties request that the initial status conference, 
scheduled for January 23, 2026, be canceled.  Given the voluminous discovery and defense 
counsel’s trial schedule, the parties request that the next status conference be scheduled in 
approximately 75 days, instead of the typical 30-45 days. 
 
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Case 1:25-cr-10455-RGS     Document 29     Filed 01/15/26     Page 2 of 3

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Respectfully submitted, 
 
DAVID EBRAHIMZADEH 
By his attorney, 
 
 
 
 
/s/ Scott Seitz   
 
 
Robert Fisher 
Scott Seitz 
Nixon Peabody LLP 
53 State St. 
Boston, MA 02109 
sseitz@nixonpeabody.com 
617.345.1000 
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 15, 2026 
 
 
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 15, 2026 
Case 1:25-cr-10455-RGS     Document 29     Filed 01/15/26     Page 3 of 3

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