Motion for Sequestration of Witnesses — United States v. Reynolds (D. Mass., Document 72)

Summary

A Motion for Sequestration of Witnesses filed January 26, 2026 as Document 72 by defendant Katherine Reynolds in United States v. Reynolds, Docket No. 24-cr-10233-MJJ, in the U.S. District Court for the District of Massachusetts. It asks the Court to order that all witnesses be sequestered from the courtroom during the trial and be instructed not to discuss their testimony with any other prospective witness. Its numbered terms ask that each witness not discuss the case with other witnesses, be excluded from the courtroom when others testify, and not tell a prospective witness what was asked or answered. The motion is signed by counsel Joan M. Fund.

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         Case 1:24-cr-10233-MJJ            Document 72         Filed 01/26/26      Page 1 of 3




                              UNITED STATES DISTRICT COURT
                               DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA

v.                                                               Docket No. 24-cr-10233-MJJ

KATHERINE REYNOLDS,
         Defendant


                       MOTION FOR SEQUESTRATION OF WITNESSES

         Now comes the Defendant in the above-numbered Indictments and moves this Court to

order that all witnesses be sequestered from the courtroom during the trial of this case and further

that all witnesses be instructed that they may not discuss the subject matter of their testimony or the

questions asked by either counsel with any other prospective witness until the conclusion of the

trial proceeds.

         The defendant moves that this Court order that each witness:

         1.       Shall not discuss this case, including but not limited to his or her prospective

                  testimony with any other witness;

         2.       Shall be excluded from the courtroom when other witnesses are testifying; and

         3.       Shall not, after testifying, tell any prospective witness what he or she was asked or

                  answered.

         Counsel for the government and defendant shall inform their prospective witnesses of this

Order.

         This Order shall not operate to prevent counsel from conferring with a witness prior to his

or her testimony. However, unless protected by attorney-client privilege or some other applicable

privilege, such communication may be explored on direct and/or cross-examination of the witness.
Case 1:24-cr-10233-MJJ   Document 72    Filed 01/26/26   Page 2 of 3




                             Respectfully submitted,
                             Katherine Reynolds
                             By her attorney,

                             /s/ Joan M. Fund
                             Joan M. Fund, Esq.
                             245 First Street
                             Suite 1800
                             Cambridge, MA 02142
                             617 444 8762
                             508 878 6830
                             BBO#181430
        Case 1:24-cr-10233-MJJ          Document 72        Filed 01/26/26      Page 3 of 3




                                 CERTIFICATE OF SERVICE

        I hereby certify that this document filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing (NEF).

                                              /s/ Joan M. Fund
                                              Joan M. Fund, Esquire
Date: January 26, 2026


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