Notice of Initial Disclosures — Pietschner v. Petralia (Eastern District of Texas, April 28, 2025)

Summary

This is the United States of America's Notice of Initial Disclosures in United States of America ex rel. Paul Pietschner v. Kathryn Petralia, Robert Frohwein, and Spencer Robinson, Civil Action No. 4:21-cv-110-SDJ, in the United States District Court for the Eastern District of Texas, Sherman Division. The notice states that on April 28, 2025 the United States served its Initial Disclosures on all parties under Federal Rule of Civil Procedure 26(a)(1)(A), and that its document production contains protected information subject to the Bank Secrecy Act. It states that a Joint Motion for Entry of a Protective Order was filed April 24, 2025 and is pending, and that the United States is prepared to produce within two days of entry of the Protective Order.

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PLAINTIFF UNITED STATES OF AMERICA’S NOTICE OF INITIAL DISCLOSURES – PAGE 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
SHERMAN DIVISION

UNITED STATES OF AMERICA
ex rel. PAUL PIETSCHNER,

Plaintiff,

v.

KATHRYN PETRALIA;
ROBERT FROHWEIN; and
SPENCER ROBINSON,

Defendants.

Civil Action No.: 4:21-cv-110-SDJ

UNITED STATES OF AMERICA’S NOTICE OF INITIAL DISCLOSURES

Pursuant to the Court’s Order Governing Proceedings (ECF No. 69) and Federal Rule of
Civil Procedure 26, Plaintiff the United States of America (the “United States”), hereby gives
notice to the Court that on April 28, 2025, the United States served on all parties, through their
counsel of record, the United States’ Initial Disclosures as provided by Federal Rule of Civil
Procedure 26(a)(1)(A), which requires only a written statement.  The Court’s Order Governing
Proceedings (ECF No. 69), also orders the parties to produce “a copy of all documents, ESI,
witness statements, and tangible things in the possession, custody, or control of the disclosing party
that are relevant to the claim or defense of any party.” ECF No. 69, p. 4 (the “Initial Disclosure
Document Production”).  The United States’ Initial Disclosure Document Production contains
protected information subject to the Bank Secrecy Act and other sensitive information subject to
protections under a protective order.
Case 4:21-cv-00110-SDJ     Document 77     Filed 04/28/25     Page 1 of 3 PageID #:  843

PLAINTIFF UNITED STATES OF AMERICA’S NOTICE OF INITIAL DISCLOSURES – PAGE 2
On April 24, 2025, the parties filed a Joint Motion for Entry of a Protective Order, Federal
Rule of Evidence 502(d) Order, and Order governing production of electronically stored
information, which is pending before this Court. ECF No. 73.
On April 25, 2025, the United States filed an unopposed motion for extension of time to
make its Initial Disclosure Document Production to await entry of a protective order given the
nature of the claims at issue and the confidential information contained in the United States’
document production. ECF No. 75.
The United States is prepared to make its initial disclosure document production within
two days of entry of the Protective Order, ECF No. 73-1.
Dated: April 28, 2025

Respectfully submitted,

MICHAEL D. GRANSTON
Deputy Assistant Attorney General

ABE MCGLOTHIN, Jr.
Acting United States Attorney
Eastern District of Texas

/s/ Betty Young____________
JAMES G. GILLINGHAM, Texas Bar
#24065295
BETTY S. YOUNG, Texas Bar #24102498
Assistant U.S. Attorneys
Eastern District of Texas
110 N. College Street, Suite 700
Tyler, Texas 75702
E-mail: James.Gillingham@usdoj.gov
E-mail: Betty.Young@usdoj.gov
(903) 590-1400
(903) 590-1436 (facsimile)

JAMIE ANN YAVELBERG
COLIN M. HUNTLEY
SARAH E. LOUCKS
KELLY E. PHIPPS
Attorneys, Civil Division
United States Department of Justice
Case 4:21-cv-00110-SDJ     Document 77     Filed 04/28/25     Page 2 of 3 PageID #:  844

PLAINTIFF UNITED STATES OF AMERICA’S NOTICE OF INITIAL DISCLOSURES – PAGE 3
P.O. Box 261
Ben Franklin Station
Washington, D.C. 20044
E-mail: Sarah.E.Loucks@usdoj.gov
E-mail: Kelly.E.Phipps@usdoj.gov
(202) 616-4203
(202) 514-0280 (facsimile)

ATTORNEYS FOR THE
UNITED STATES OF AMERICA

CERTIFICATE OF SERVICE

I hereby certify that on April 28, 2025, I caused a true and correct copy of the foregoing
document to be transmitted through the Court’s electronic mailing service (CM/ECF) to all counsel
of record who have consented to electronic service by the Court’s electronic mailing service
(CM/ECF).

/s/ Betty Young__________

BETTY S. YOUNG

Case 4:21-cv-00110-SDJ     Document 77     Filed 04/28/25     Page 3 of 3 PageID #:  845

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