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Home Court filings United States v. Adiana Pierre, Erin Jare Brown, Gardy Alexandre, and Wallace Billy Ford Government's Motion to Dismiss Criminal Complaint as to Erin Brown — United States v. Brown (D. Mass.)

Court filing

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

Filed January 16, 2024 in U.S. v. Brown; one of 3 filings from this case.

Record facts

CourtU.S. District Court for the District of Massachusetts
Filed2024-01-16

U.S. District Court for the District of Massachusetts · No. 1:23-mj-05013-JGD · Doc. 38 · 2024-01-16 · Docket on CourtListener

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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