Assented-To Motion for Discovery Protective Order — United States v. Ebrahimzadeh

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An assented-to motion for a discovery protective order 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, dated January 14, 2026 and marked Document 28. Under Federal Rule of Criminal Procedure 16(d), the government seeks an order protecting Social Security numbers, dates of birth, home addresses and bank account numbers of unindicted co-conspirators and witnesses in over 1.3 million pages of discovery. It states that the indictment charges bank fraud, wire fraud affecting a financial institution, wire fraud, and procuring the filing of a false tax return, and alleges the defendant fraudulently obtained over $8 million in pandemic relief loans. Materials designated "Confidential" would be kept by defense counsel and viewed with counsel.

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Case 1:25-cr-10455-RGS Document 28 Filed 01/18/26 Page1of4

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA

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

ASSENTED-TO MOTION FOR DISCOVERY PROTECTIVE ORDER

Pursuant to Federal Rule of Criminal Procedure 16(d), the government, with the assent of
the defendant, hereby moves for the entry of a protective order, which will enable the government
to produce relevant evidence to the defendant while protecting confidential or sensitive
information, including Social Security numbers, dates of birth, home addresses, and bank account
numbers of unindicted co-conspirators and witnesses, as well as other information that could pose
a serious risk of harm to an individual or entity or risk obstructing the government’s ongoing
investigation if disseminated. As grounds for this motion, the government states as follows:

The indictment charges the defendant with bank fraud, wire fraud affecting a financial
institution, wire fraud, and procuring the filing of a false tax return. The indictment alleges that
the defendant fraudulently obtained over $8 million in pandemic relief loans from the United States
by making false statements in support of those applications and applying on behalf of ineligible
and defunct entities. The indictment refers to numerous individuals (at {J 3-8) who were involved
in the defendant’s fraudulent activities. Although only the defendant is charged in the indictment,
the government’s investigation is ongoing, and there are multiple unindicted co-conspirators, with

whom the defendant has been ordered to have no contact.
Case 1:25-cr-10455-RGS Document 28 Filed 01/18/26 Page 2of4

The government will be producing in automatic discovery over 1.3 million pages of
documents. Some of these documents contain the personal identifying information and sensitive
financial information of witnesses and unindicted co-conspirators, as well as the defendant.
Moreover, some of the materials that the government will be producing in automatic discovery,
including a portion of a phone extraction, text messages, and contents of email accounts, contain
personal and sensitive information of witnesses and unindicted co-conspirators. Given the scope
of the production, redacting PII and other personal and sensitive information from these documents
is impractical. Moreover, the dissemination of some of these materials could pose a risk to the
integrity of the government’s ongoing investigation and/or a risk of harm to an individual.

The government wishes to provide these materials promptly. However, given the volume
of discovery, it would be impractical to apply redactions to all personally identifying information
such as dates of birth and social security numbers, or other potentially sensitive information such
as bank account numbers.

For these reasons, the government moves, pursuant to Rule 16 of the Federal Rules of
Criminal Procedure and Local Rules 7.2 and 116.6, for a protective order and proposes that the
Court enter the order attached.

The proposed protective order differentiates between classes of discovery material, with
some materials subject to greater restrictions than others. The proposed protective order provides
that all discovery materials may only be used for the defense of this case and cannot be further
distributed except under narrow circumstances. It further provides that for any particularly
sensitive documents that the government designates as “Confidential” (“Confidential Discovery

Materials”), while the defendant may view the materials, he may not personally possess a copy;
Case 1:25-cr-10455-RGS Document 28 Filed 01/14/26 Page3of4

those items are to be maintained by his counsel and viewed with his counsel. The government
anticipates using this designation sparingly.

Any Confidential Discovery Materials that are filed with the Court in connection with pre-
trial motions, trial, sentencing, or other matters before this Court shall be filed under seal and shall
remain sealed until otherwise ordered by this Court. The Protective Order does not entitle either
party to seal its filings as a matter of course; it requires the parties to comply in all respects with
the relevant local and federal rules of criminal procedure pertaining to the sealing of court
documents. It permits the parties to seek modifications of the Protective Order in the future and

permits the defendant to challenge any confidentiality designation made by the government.

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

Jan 16, 2026

Ee David H. Hennessy |

Dated: January 14, 2026
Case 1:25-cr-10455-RGS Document 28 Filed 01/18/26 Page4of4

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

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 14, 2026


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