Court filing

Government Motion to Dismiss — U.S. v. Bushell & Stockton

Summary

Motion to Dismiss Criminal Complaint filed November 8, 2023 as Document 58 in United States v. Brian Andrew Bushell and Tracey M.A. Stockton, No. 22-MJ-04506-DHH, U.S. District Court for the District of Massachusetts. Under Federal Rule of Criminal Procedure 48(a), the United States Attorney seeks leave to dismiss the complaint charging both defendants with conspiracy to commit wire fraud under 18 U.S.C. 1349 and conspiracy to commit unlawful monetary transactions under 18 U.S.C. 1956(h). The government states only that dismissal is in the interests of justice. Assistant U.S. Attorney David M. Holcomb signed /s/ for Acting U.S. Attorney Joshua S. Levy.

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Filed November 8, 2023 in U.S. v. Bushell Stockton; one of 2 filings from this case.

Record facts

Court	U.S. District Court, D. Mass.
Filed	2023-11-08

Cite this document

“Government Motion to Dismiss — U.S. v. Bushell & Stockton.” U.S. District Court, D. Mass., No. 1:22-mj-04506-DHH, Doc. 58, filed 2023-11-08. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-bushell-stockton-mad/2023-11-08-motion-to-dismiss/, SHA-256 fddbdd5a1d1bf3a1ed2869d4e32bd1e487959acc1e408ca0af6a1567081cb1b8.

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Full text

UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 
   
 
UNITED STATES OF AMERICA 
 
) 
) 
 
 
v.  
 
 
 
 
)   No. 22-MJ-04506-DHH 
) 
 
BRIAN ANDREW BUSHELL and 
 
) 
TRACEY M.A. STOCKTON,  
 
) 
 
 
 
 
 
 
 
) 
 
 
 
Defendants 
 
 
) 
 
 
 
 
 
 
 
 
 
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 
against defendants Brian Andrew Bushell and Tracey M.A. Stockton in this matter, charging them 
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: November 8, 2023 
 
 
Case 1:22-mj-04506-DHH   Document 58   Filed 11/08/23   Page 1 of 2

 
2 
 
CERTIFICATE OF SERVICE 
 
I hereby certify that this document was filed through the ECF system on November 8, 2023 
and will be sent electronically to the registered participants identified on the Notice of Electronic 
Filing (NEF).  
 
Dated:  November 8, 2023 
 
 
 
By: 
/s/ David M. Holcomb  
 
 
DAVID M. HOLCOMB 
Assistant United States Attorney 
 
 
Case 1:22-mj-04506-DHH   Document 58   Filed 11/08/23   Page 2 of 2

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File: 001_ECF_58_gov.uscourts.mad.249170.58.0.pdf
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SHA-256: fddbdd5a1d1bf3a1ed2869d4e32bd1e487959acc1e408ca0af6a1567081cb1b8
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