Unopposed Motion for Protective Order by USA — United States v. Metelus (Dkt. 11, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 0:26-cr-60019-RKA · Doc. 11 · 2026-02-09 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO. 26-CR-60019-ALTMAN/STRAUSS 
 
 
UNITED STATES OF AMERICA  
 
 
 
 
 
 
 
vs. 
 
 
 
 
 
 
 
 
 
 
 
 
 
ROODY METELUS, 
 
 
 
 
 
 
 
 
Defendant. 
 
 
 
_________________________________/ 
 
UNOPPOSED MOTION BY THE UNITED STATES  
FOR A PROTECTIVE ORDER REGULATING DISCLOSURE OF  
DISCOVERYAND SENSITIVE INFORMATION CONTAINED THEREIN 
 
 
Pursuant to Federal Rule of Criminal Procedure 16(d), the United States of America files 
this motion for a protective order regulating disclosure of the discovery materials in this case and 
certain sensitive information contained therein (the “Discovery”). The defendant in this case is 
charged with conspiracy to commit wire fraud stemming from the preparation and submission of 
more than 200 false and fraudulent Paycheck Protection Program (“PPP”) loan applications with 
false and fraudulent supporting tax documents, in violation of 18 U.S.C. § 371.  Some of the 
discovery materials that the government will make available to the defense includes, among other 
things, IRS tax returns and other tax documents containing personally identifiable information of 
taxpayers, as well as loan documents and other documents containing sensitive personal and 
financial information about the loan applicants (collectively, the “Sensitive Information”). Given 
the volume and format of Sensitive Information in this case, it is not practicable for the government 
to redact it.  Accordingly, in order to ensure the protection of the Sensitive Information and to 
avoid the disclosure of this information to other individuals, the government requests that the Court 
enter an order regulating disclosure of discovery as follows:  
Case 0:26-cr-60019-RKA   Document 11   Entered on FLSD Docket 02/09/2026   Page 1 of 3

 
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1. 
The government is authorized to disclose Sensitive Information in its possession 
that the government believes necessary to comply with the discovery obligations imposed by this 
Court;  
2. 
The government shall produce the Discovery as follows. The government shall 
mark that portion of the Discovery that includes Sensitive Information as “Confidential,” which 
will be governed by the following rules.   
3. 
With respect to the Confidential portion of the Discovery, the following rules shall 
apply:  
a. 
Counsel of record for defendant in this proceeding shall hold the 
Confidential portion of the Discovery in strictest confidence.  Therefore, defense counsel shall 
restrict access to this discovery, and shall disclose this discovery to their client, office staff, 
investigators, and to anticipated fact or expert witnesses only to the extent that defense counsel 
believes is necessary to assist in the defense of their clients in this matter and in a manner that will 
prohibit the disclosure of this discovery to other persons not involved in the defense;   
b. 
Counsel of record for defendant shall advise any person to whom the 
Confidential portion of the Discovery is disclosed that such information shall be held in strict 
confidence, and that further disclosure or dissemination is prohibited without defense counsel’s 
express consent; and  
c. 
Counsel of record for defendant shall obtain a certification from each person 
to whom the Confidential portion of the Discovery is disclosed, in which the recipient, (a) 
acknowledges these restrictions as set forth in the Protective Order of the Court, and (b) agrees 
that they will not disclose or disseminate the information without express consent of defense 
counsel.  Counsel shall keep a copy of each certification to identify the individuals who received 
Case 0:26-cr-60019-RKA   Document 11   Entered on FLSD Docket 02/09/2026   Page 2 of 3

 
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the Confidential portion of the Discovery and the date on which such information was first 
disclosed.  
d. 
Counsel of record agrees that, upon conclusion of the above captioned case, 
copies of the Confidential portion of the Discovery disclosed to defense counsel pursuant to the 
terms of this order shall be destroyed or returned to the United States.   
 
Pursuant to Local Rule 88.9, the undersigned Assistant United States Attorney has 
conferred with counsel of record for the Defendant regarding this motion, and counsel has 
indicated that he has no objection to the relief requested.  
 
 
 
 
     Respectfully Submitted, 
 
 
 
          JASON A. REDING QUIÑONES 
          UNITED STATES ATTORNEY  
 
 
By:       /s/ Aimee C. Jimenez                      
 
AIMEE C. JIMENEZ 
Assistant United States Attorney 
Court ID No. A5500795 
99 N.E. 4th Street, 4th Floor 
Miami, FL 33132 
Tel: (305) 961-9028 
Email: aimee.jimenez@usdoj.gov 
 
 
 
 
 
 
 
 
 
 
Case 0:26-cr-60019-RKA   Document 11   Entered on FLSD Docket 02/09/2026   Page 3 of 3

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