Proposed Protective Discovery Order — United States v. Tavaris Johnson (Document 21, filed March 14, 2026)

Summary

A Proposed Protective Discovery Order in United States v. Tavaris Johnson, Case No. 8:26-cr-77-KKM-NHA, in the U.S. District Court for the Middle District of Florida, Tampa Division, Document 21, filed March 14, 2026. It states that the parties' joint motion for a protective discovery order, under Federal Rule of Criminal Procedure 16(d)(1), would be granted. The order would define "Protected Materials" to include any records identifying a child, personally identifiable information and sensitive personal information, and would let the government produce them to the Defense Team. The Defense Team would be forbidden from giving or leaving Protected Materials with the defendants and from sharing them with third parties without permission from the Court, and would use them solely for preparing for trial. The signature block names United States Magistrate Judge Natalie Hirt Adams.

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Case 8:26-cr-00077-KKM-NHA       Document 21     Filed 03/14/26    Page 1 of 3 PageID 50




                       UNITED STATES DISTRICT COURT
                        MIDDLE DISTRICT OF FLORIDA
                              TAMPA DIVISION

 UNITED STATES OF AMERICA

       v.                                  CASE NO. 8:26-cr-77-KKM-NHA

 TAVARIS JOHNSON

                                PROPOSED
                       PROTECTIVE DISCOVERY ORDER

       The matter before the Court is the parties’ joint motion for a protective

 discovery order. The parties’ motion, having been read and considered, there being

 good cause for a protective discovery order pursuant to Federal Rule of Criminal

 Procedure 16(d)(1), and the parties having stipulated and agreed to the entry of a

 protective discovery order, the Court finds it appropriate to grant the motion.

       It is hereby ORDERED that:

       1.     The term “Protected Materials” includes any records identifying a

 child, “personally identifiable information” (PII), and any “sensitive personal

 information” (SPI).

       2.     PII includes any information that identifies the unique identity of an

 individual, including but not limited to name, gender, address, telephone, email

 address, date of birth, maiden name, social security number, driver’s license number,

 or biometric data.

       3.     SPI includes information about an individual that if lost, compromised,

 or disclosed could result in substantial harm, embarrassment, inconvenience, or
Case 8:26-cr-00077-KKM-NHA        Document 21      Filed 03/14/26    Page 2 of 3 PageID 51




 unfairness to the individual or others.

       4.     The term “Defense Team” refers to (a) defendant’s counsel of

 record, (b) any other attorney at defense counsel’s law firm who may be consulted

 regarding case strategy in the above-captioned matter, (c) defense investigators who

 may assist defense counsel with this case, (d) any retained experts or potential

 experts, and (e) paralegals, legal assistants, and other support staff to defendant’s

 counsel of record—all of whom have been advised of their obligations under the

 Protective Order and have affirmed to defendant’s counsel of record that they all

 agree to be bound by the terms of the Protective Order. The term “Defense Team”

 does not include the defendants, their family members, any associates of the

 defendants, potential lay witnesses, or any other third parties.

       5.     The defendant’s counsel of record shall advise all members of the

 Defense Team of their obligations under this Order prior to providing members of

 the Defense Team with access to any Protected Materials.

       6.     The government may produce Protected Materials to the Defense Team

 or allow the Defense Team to access Protected Materials.

       7.     Upon receiving Protected Materials, the Defense Team shall treat such

 materials, including copies of such materials and any subsequent notes regarding said

 materials, as confidential. Specifically, the Defense Team is forbidden from giving

 the Protected Materials with the defendants themselves, and is not permitted to leave

 Protected Materials with the defendants. In other words, the Defense Team may

 discuss the Protected Materials with the defendant, but never give or leave Protected

                                           2
Case 8:26-cr-00077-KKM-NHA       Document 21     Filed 03/14/26    Page 3 of 3 PageID 52




 Materials with the defendant. Further, the Defense Team is not permitted to share

 the Protected Materials in any way with third parties without permission from the

 Court.

          8.   The Defense Team shall access and use Protected Materials for the sole

 purpose of preparing for trial. To the extent that notes are made that memorialize,

 on whole or in part, the Protected Materials, or to the extent that copies are made for

 authorized use by members of the Defense Team, such notes, copies, or

 reproductions themselves become Protected Materials and must be handled in

 accordance with this Order.

          DONE AND ORDERED in Chambers at Tampa, Florida, this 14th               day

 of March, 2026.


                                  ___________________________________________
                                 HONORABLE NATALIE HIRT ADAMS
                                 United States Magistrate Judge




                                         3


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