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Defendants' Unopposed Joint Discovery Motion — No. 3:25-cr-00106 (Dkt. 39, W.D.N.C.)

Summary

A defendants' unopposed joint discovery motion filed in the U.S. District Court for the Western District of North Carolina, Charlotte Division, in United States v. Tiawana Brown, et al., Docket No. 3:25CR106, docketed as 3:25-cr-00106, as Document 39 of 4 pages. Brown, jointly with her codefendants and without opposition from the Government, asks the Court to let the defense treat discovery documents containing the personal identifying information of codefendants as non-sensitive discovery under the Standard Discovery Order. The motion states that the order keeps sensitive materials in counsel's custody, that the three codefendants are related and each consents to the others receiving documents with their PII, and that AUSA Matt Warren does not oppose. A proposed order for the presiding Magistrate Judge, dated June, 2025, follows.

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Cite this document

“Defendants' Unopposed Joint Discovery Motion — No. 3:25-cr-00106 (Dkt. 39, W.D.N.C.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/defendants-unopposed-joint-discovery-motion-no-3-25-cr-00106-dkt-39-w-cac6cc3662/, SHA-256 7d5cc5f527e4db58b3702012cb81fbedaa539c9dd820bca1b7112db5a9a52d23.

Full text

             UNITED STATES DISTRICT COURT FOR THE
             WESTERN DISTRICT OF NORTH CAROLINA
                      CHARLOTTE DIVISION

UNITED STATES OF AMERICA
               Plaintiff,            )     DOCKET NO: 3:25CR106
            v.                       )
TIAWANA BROWN, et. al,               )     DEFENDANTS’ UNOPPOSED
               Defendant.            )     JOINT DISCOVERY MOTION
                                     )

       Defendant Tiawana Brown, jointly with her codefendants, and without

 opposition by the Government, requests that the Court permit the Defense to

 treat discovery documents containing PII of codefendants as non-sensitive

 discovery. Non-sensitive discovery may be provided directly to the defendants

 in accordance with the discovery order.

       1. This case is governed under the Standard Discovery Order. See
          Docket Entry at 5/23/25.
       2. That order provides that “sensitive materials” shall remain in the
          custody of counsel and not be provided to a defendant.
       3. It defines sensitive material (in relevant part) as material
          containing personal identifying information of another person.
       4. In this case, the three codefendants are related, and each consent to
          the other receiving copies of documents that might contain their PII,
          and to otherwise treat that material as “non-sensitive.”
       5. All defendants join in this motion.
       6. The Government, through AUSA Matt Warren, does not oppose this
          motion.
       Defendant therefore moves the Court to allow the Defense to treat

 material containing the PII of a codefendant as ‘non-sensitive’ consistent with

 the enclosed proposed order.




    Case 3:25-cr-00106-KDB-SCR     Document 39    Filed 06/09/25   Page 1 of 4
  Respectfully submitted, this the 9th day of June, 2025.



                                 s/ Rob Heroy
                                 W. Rob Heroy
                                 Bar No. 35339
                                 Goodman Carr, PLLC
                                 301 S. McDowell St., #602
                                 Charlotte, NC 28204
                                 Telephone: (704)-372-2770
                                 rheroy@goodmancarr.net



                                s/ Kimberly Best
                                Kimberly Best
                                Counsel for Tijema Brown

                                s/Habekah Cannon
                                Habekah Cannon
                                Counsel for Antoinette Rouse




                                   2
Case 3:25-cr-00106-KDB-SCR    Document 39    Filed 06/09/25   Page 2 of 4
                      CERTIFICATE OF SERVICE

      I certify that I have served the foregoing MOTION on opposing counsel
and all other parties, via ECF using the CM-ECF system, which will send
notice of such filing to all registered CM/ECF users.

     This the 9TH day of June, 2025.

                                   s/ Rob Heroy
                                   W. Rob Heroy




                                       3
   Case 3:25-cr-00106-KDB-SCR   Document 39   Filed 06/09/25   Page 3 of 4
              UNITED STATES DISTRICT COURT FOR THE
              WESTERN DISTRICT OF NORTH CAROLINA
                       CHARLOTTE DIVISION

UNITED STATES OF AMERICA
               Plaintiff,             )       DOCKET NO: 3:25CR106
            v.                        )
TIAWANA BROWN, et. al,                )       PROPOSED ORDER
               Defendant.             )
                                      )

       This matter is before the Court based on an unopposed motion filed by

 Defendant Tiawana Brown, and joined by Codefendants Tijema Brown and

 Antoinette Rouse, requesting that the Court permit the defendants to treat

 materials containing the PII of codefendants as non-sensitive discovery

 material.

       This motion is ALLOWED. If discovery in this case is deemed “sensitive

 material” based solely on the inclusion of personally identifying information of

 a codefendant, Defendants may treat that material as non-sensitive material.

 As such, Counsel may provide copies of that material to their clients.

       All other provisions of the order remain in effect.

       This is the ____ day of June, 2025.



                                               _________________________
                                               Magistrate Judge Presiding




                                          4
    Case 3:25-cr-00106-KDB-SCR      Document 39      Filed 06/09/25   Page 4 of 4


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