Joint Motion for Protective Order by Christopher Howard — USA v. Harun (Dkt. 64, S.D. Ga.)

Summary

A Joint Motion for a Protective Order Governing Certain Discovery in United States of America v. Gladys Harun, Case No. 3:22-CR-09, in the U.S. District Court for the Southern District of Georgia, Dublin Division, filed September 26, 2022 as Doc. 64. The United States and counsel for Defendant Gladys Harun jointly seek a protective order concerning information produced in response to three recent search warrants: a cellular phone (doc. 59), a Google email address (doc. 55), and a Yahoo email address (doc. 51). The motion states that the materials may include privileged information and describes a process to keep it from case agents, investigators, and prosecutors. The signature block lists /s/ Chris Howard, Assistant United States Attorney, and /s/ D. Robert Busbee, Counsel for Defendant.

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UNITED STATES DISTRICT COURT  
SOUTHERN DISTRICT OF GEORGIA 
DUBLIN DIVISION 
 
UNITED STATES OF AMERICA 
) 
 
 
 
 
 
 
 
) 
v. 
 
 
 
 
 
) 
CASE NO: 3:22-CR-09 
 
 
 
 
 
 
) 
 
 
 
 
 
 
GLADYS HARUN 
  
 
) 
 
 
 
 
 
 
 
 
JOINT MOTION FOR A PROTECTIVE ORDER 
GOVERNING CERTAIN DISCOVERY 
 
The United States and counsel for Defendant Gladys Harun jointly seek a 
protective order concerning the disclosure of information produced in response to 
three recent search warrants.  Such warrants encompass a cellular phone (doc. 59), a 
Google email address (doc. 55), and a Yahoo email address (doc. 51). 
There is a reasonable possibility that materials to be reviewed from the return 
of such warrants may include privileged information.  Accordingly, the parties have 
conferred regarding a process they believe appropriate to (1) protect Defendant’s 
attorney-client and work-product privileges as well as Defendant’s Constitutional 
rights, and (2) to prevent the disclosure of privileged and/or otherwise 
Constitutionally protected attorney-client information to case agents, investigators, 
and prosecutors assigned to the investigation.  Such process is set forth in the 
proposed order. 
WHEREFORE, the United States and counsel for Defendant Gladys Harun 
respectfully request the Court enter a protective order as set forth in the parties’ 
proposed submission. 
 
Case 3:22-cr-00009-DHB-BKE     Document 64     Filed 09/26/22     Page 1 of 2

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Respectfully submitted, 
 
 
 
 
 
/s/ Chris Howard                                 .       /s/ D. Robert Busbee  
Chris Howard 
 
 
 
      D. Robert Busbee 
Assistant United States Attorney 
      Counsel for Defendant 
 
N.Y. Bar Number 4935938 
 
      Georgia Bar Number 186336 
P.O. Box 8970 
 
 
 
      Busbee Law Group LLC 
Savannah, GA 31412           
 
      8 E. Grady St. 
                                                                       Statesboro, GA 30458  
 
Case 3:22-cr-00009-DHB-BKE     Document 64     Filed 09/26/22     Page 2 of 2

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