Court filing
Information - United States v. Shibley companion docket
Record facts
| Court | U.S. District Court for the Western District of Washington |
|---|---|
| Filed | 2020-10-23 |
U.S. District Court for the Western District of Washington · No. 2:20-cr-00174-JCC · Doc. 38 · 2020-10-23 · Docket on CourtListener
Summary
A stipulated motion for entry of a protective order in United States of America v. Eric Shibley, No. CR20-174JCC, in the U.S. District Court for the Western District of Washington, filed October 23, 2020 as Document 38 before Judge John C. Coughenour. The motion states that the Indictment alleges the defendant submitted Payroll Protection Program and Economic Injury Disaster Loan applications that misrepresented employees, payroll, revenues and his probation status. It says discovery will include personal identifying information protected under Fed. R. Crim. P. 49.1 and asks that such material be treated as Protected Material, provided only to counsel and staff. It states that pre-indictment discovery produced under a Confidentiality Agreement dated July 15, 2020 will be governed by the attached protective order. It is signed by government attorneys and defense counsel Michael Nance.
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United States v. Eric Shibley
CR20-174JCC, Stipulated Motion for Entry of a Protective Order - 1
UNITED STATES ATTORNEY
700 STEWART ST, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970
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The Honorable John C. Coughenour
UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE
UNITED STATES OF AMERICA,
Plaintiff,
v.
ERIC SHIBLEY,
Defendant.
NO. CR20-174JCC
STIPULATED MOTION FOR ENTRY
OF A PROTECTIVE ORDER
Noted: October 23, 2020
I.
INTRODUCTION
The United States of America, by and through Brian T. Moran, United States
Attorney for the Western District of Washington, Brian Werner, Assistant United States
Attorney for the Western District of Washington, Daniel S. Kahn, Acting Chief, Fraud
Section, Department of Justice, Laura Connelly and Amanda R. Vaughn, Trial Attorneys,
and the defendant, ERIC SHIBLEY, by and through his attorney Michael Nance, hereby
move for entry of a protective order regarding the discovery materials described below.
II.
THE NEED FOR A PROTECTIVE ORDER
The Indictment in this case alleges that Defendant Shibley, through various
entities he controlled, submitted fraudulent Payroll Protection Program (“PPP”) and
Economic Injury Disaster Loan (“EIDL”) applications which falsely represented the
Case 2:20-cr-00174-JCC Document 38 Filed 10/23/20 Page 1 of 3
United States v. Eric Shibley
CR20-174JCC, Stipulated Motion for Entry of a Protective Order - 2
UNITED STATES ATTORNEY
700 STEWART ST, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970
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number of employees, monthly payroll expenses, and gross revenues of the Shibley
entities, as well as Shibley’s probation status. The discovery in this case will contain the
personal information of certain individuals the Defendant claimed as employees of his
business, including personal identifying information that is protected from disclosure
under applicable law, including Fed. R. Crim. P. 49.1. Furthermore, documents involved
in this case may include information concerning business and financial information or
data.
The parties stipulate to the entry of the attached protective order to ensure that
personal information is treated as “Protected Material” and not used for any other
purpose than preparing a defense in this matter, and that copies of Protected Materials
may only be provided to counsel and counsel’s staff. The government will identify what
is “Protected Material” at the time it produces it to defense. However, counsel may
review Protected Material with clients and witnesses, so long as they do not provide the
client/witness with a copy of the Protected Material.
The personal information of any witness may not be filed or used in Court without
redaction or further order of the Court. See Local Rules W.D. Wash., CrR 49.1.
The government provided pre-indictment discovery to the Defendant in July 2020,
pursuant to a Confidentiality Agreement dated July 15, 2020. The parties agree that all
previously produced discovery shall now be governed by the attached protective order.
//
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Case 2:20-cr-00174-JCC Document 38 Filed 10/23/20 Page 2 of 3
United States v. Eric Shibley
CR20-174JCC, Stipulated Motion for Entry of a Protective Order - 3
UNITED STATES ATTORNEY
700 STEWART ST, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970
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III.
CONCLUSION
For the foregoing reasons, the parties respectfully request that the Court enter the
attached protective order.
Dated this 23rd day of October 2020.
Respectfully submitted,
Brian T. Moran
United States Attorney
s/ Brian Werner
BRIAN WERNER
Assistant United States Attorney
700 Stewart Street, Suite 5220
Seattle, Washington 98101
Telephone: (206) 553-7970
E-mail: brian.werner@usdoj.gov
Daniel S. Kahn
Acting Chief, Fraud Section
s/ Laura Connelly
LAURA CONNELLY
AMANDA R. VAUGHN
Trial Attorneys
1400 New York Avenue NW
Washington, DC 20005
Telephone: (202) 307-1423
E-mail: laura.connelly@usdoj.gov
Per email authorization:
s/ Michael Nance
MICHAEL NANCE
Attorney for Eric Shibley
Case 2:20-cr-00174-JCC Document 38 Filed 10/23/20 Page 3 of 3File and source
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