Court filing

Government's Motion to Dismiss Criminal Complaint as to Erin Brown — United States v. Brown (D. Mass.)

Summary

A Motion to Dismiss Criminal Complaint filed January 16, 2024 as Document 38 in United States of America v. Erin Brown, No. 23-MJ-05013-JGD, in the U.S. District Court for the District of Massachusetts. Under Federal Rule of Criminal Procedure 48(a), the United States Attorney for the District of Massachusetts seeks leave of the court to dismiss the criminal complaint as to Erin Brown. The complaint charges conspiracy to commit wire fraud, 18 U.S.C. § 1349, and conspiracy to commit unlawful monetary transactions, 18 U.S.C. § 1956(h). The government states that dismissal is in the interests of justice. The motion is signed /s/ David M. Holcomb, Assistant United States Attorney.

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Filed January 16, 2024 in U.S. v. Brown; one of 35 filings from this case.

Record facts

Court	U.S. District Court for the District of Massachusetts
Filed	2024-01-16

Cite this document

“Government's Motion to Dismiss Criminal Complaint as to Erin Brown — United States v. Brown (D. Mass.).” U.S. District Court for the District of Massachusetts, No. 1:23-mj-05013-JGD, Doc. 38, filed 2024-01-16. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-brown/2024-01-16-motion-to-dismiss-complaint/, SHA-256 094605e0f74659d715b53d280d2139f5f3d90223c086d841f0e3caff29b5aaa2.

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Full text

UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 
   
 
UNITED STATES OF AMERICA 
 
) 
) 
 
 
v.  
 
 
 
 
)   No. 23-MJ-05013-JGD 
) 
 
ERIN BROWN,  
 
 
 
) 
 
 
 
 
 
 
 
) 
 
 
 
Defendant 
 
 
) 
 
 
 
 
 
 
 
 
 
MOTION TO DISMISS CRIMINAL COMPLAINT 
 
Pursuant to Federal Rule of Criminal Procedure 48(a), the United States Attorney for the 
District of Massachusetts hereby seeks leave of this Court to dismiss the criminal complaint filed 
in this matter as to Erin Brown, charging her with conspiracy to commit wire fraud, in violation of 
18 U.S.C. § 1349, and conspiracy to commit unlawful monetary transactions, in violation of 18 
U.S.C. § 1956(h).  The government respectfully submits that dismissal is in the interests of justice.  
 
 
 
 
 
 
 
 
Respectfully submitted, 
 
JOSHUA S. LEVY 
 
 
 
 
 
 
 
ACTING UNITED STATES ATTORNEY 
 
 
 
 
 
 
 
By: 
/s/ David M. Holcomb  
 
 
DAVID M. HOLCOMB 
Assistant United States Attorney 
 
Date: January 16, 2024 
 
 
Case 1:23-mj-05013-JGD     Document 38     Filed 01/16/24     Page 1 of 2

 
2 
 
CERTIFICATE OF SERVICE 
 
I hereby certify that this document was filed through the ECF system and will be sent 
electronically to the registered participants identified on the Notice of Electronic Filing (NEF).  
 
Dated:  January 16, 2024 
 
 
 
By: 
/s/ David M. Holcomb  
 
 
DAVID M. HOLCOMB 
Assistant United States Attorney 
 
 
Case 1:23-mj-05013-JGD     Document 38     Filed 01/16/24     Page 2 of 2

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