United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 348: Memorandum opinion and order denying the defendants' joint motion to compel discovery (2025-11-14)

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Memorandum Opinion and Order in United States v. Reis and Hockridge, Criminal Action No. 4:24-CR-00287-O, Document 348, filed November 14, 2025, in the U.S. District Court for the Northern District of Texas, Fort Worth Division. The order addresses the Joint Motion to Compel Discovery (Doc. 329-1) of Defendants Nathan Reis and Stephanie Hockridge, which asks the Court to compel the Government to produce borrower and co-conspirator materials and phone records of Eric Karnezis from March 1, 2020 to December 31, 2020. The Court reasons that Federal Rule of Criminal Procedure 16 does not apply to sentencing proceedings and declines to extend the Government's Brady and Giglio obligations to the District of Oregon. It denies the motion to compel and denies the request for hearing (Doc. 330) as moot.

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“United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 348: Memorandum opinion and order denying the defendants' joint motion to compel discovery (2025-11-14).” Original at storage.courtlistener.com. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/united-states-v-reis-and-hockridge-n-d-tex-no-4-24-cr-00287-o-doc-348-9f3bcf5116/, SHA-256 ea7c5d6806947b99efb5bd6c34ede7ce0854a40e822a7c462c2405ef5fa3ece8.

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Case 4:24-cr-00287-O Document 348 Filed 11/14/25 Page 1 of 5 PageID 8631

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION

UNITED STATES OF AMERICA §
§
Plaintiff, §
§
v. § Criminal Action No. 4:24-CR-00287-O
§
NATHAN REIS (01) §
STEPHANIE HOCKRIDGE (02) §
§
Defendants. §

MEMORANDUM OPINION AND ORDER

Before the Court are Defendants Nathan Reis and Stephanie Hockridge’s Joint Motion to

Compel Discovery (Doc. 329-1); the Government’s1 Response in Opposition (Doc. 332-1); and

Defendants’ Joint Reply (Doc. 335-1). Defendants ask this Court to compel the Government to

produce “(1) materials related to borrowers identified in Mr. Moncure Dillingham’s Memorandum of

Interview (“MOI”), Mr. Fredrico Williams’s interview transcript, and Mr. Alberto Carson’s

interview transcript, as well as materials related to certain co-conspirators identified in the plea

agreements of Mr. Eric Karnezis and Mr. Anthony Karnezis; (2) materials related to 79 borrowers

listed as “Convicted” or “Cooperator Proffer” in the [G]overnment’s Loss Spreadsheet (as defined

below); (3) Eric Karnezis’s phone records from March 1, 2020 to December 31, 2020, to the extent

collected; (4) any phone records collected from Mr. Fredrico Williams; and (5) any other

discoverable documents or materials that would serve as exculpatory and/or impeaching evidence

in Mr. Reis or Ms. Hockridge’s cases, or are subject to disclosure under Rule 16 of the

Federal Rules of Criminal Procedure, to the extent not already produced.”2 Upon review, the

relief requested by Defendants is DENIED. Defendants have already laid

1
For purposes of this Order, the “Government” refers to the prosecution team of Northern District of Texas,
unless otherwise stated.
2
Defs.’ Mot. Compel 1, Doc. 329-1.
Case 4:24-cr-00287-O Document 348 Filed 11/14/25 Page 2 of 5 PageID 8632

out the factual background in their briefing and the Government has not disputed it, so the Court does

not spend time reciting it here. 3

I. APPLICABLE LAW

The Federal Rules of Criminal Procedure generally govern what information is discoverable and

when a party may obtain such information in a criminal case. United States v. Murdock, 548 F.2d 599,

602 (5th Cir. 1977). “As a matter of general construction, the measure of discovery permitted by the

Rules of Criminal Procedure is not intended to be as broad as in a civil case.” United States v. Ross, 511

F.2d 757, 762 (5th Cir. 1975) (citation and quotation omitted).

A. Rule 16

Federal Rule of Criminal Procedure 16 governs general discovery in criminal cases. United

States v. Armstrong, 517 U.S. 456, 461 (1996). Under Rule 16(a)(1)(E) of the Federal Rules of Criminal

Procedure, “[u]pon a defendant’s request” the government must produce “documents . . . within the

government’s possession, custody, or control . . . [that are] . . . material to preparing the defense.” See

Fed. R. Crim. P. 16(a)(1)(E). However, “this rule [does not] authorize the discovery or inspection of

statements made by prospective government witnesses except as provided in 18 U.S.C. § 3500.” See

Fed. R. Crim. P. 16(a)(2).

B. Brady and Giglio

The requirement of disclosure under Brady v. Maryland is a constitutional mandate which seeks

to guarantee fair criminal trials by requiring the government to disclose all material exculpatory and

impeaching evidence regardless of whether a defendant requests it. 373 U.S. 83, 86–87 (1963) (defining

exculpatory evidence as evidence that is both favorable to the accused and “material either to guilt or to

punishment.”); United States v. Bagley, 473 U.S. 667, 682 (1985) (stating that evidence is material “only

if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the

3
Id. at 2–7.
Case 4:24-cr-00287-O Document 348 Filed 11/14/25 Page 3 of 5 PageID 8633

proceeding would have been different.”). Moreover, it is the duty of the government “to learn of any

favorable evidence known to the others acting on the government’s behalf . . . including the

police.” Kyles v. Whitley, 514 U.S. 419, 437 (1995). The Government is also required to produce

impeachment evidence or evidence which shows a government witness’s bias or interest and thereby

affects the credibility of the witness’s testimony. Giglio, 405 U.S. at 153–55 (applying Brady to

evidence affecting the credibility of key government witnesses).

II. ANALYSIS

A. The Government’s Discovery Obligations Under Rule 16

Defendants seek to compel discovery pursuant to Rule 16(a)(1)(E) of the Federal Rules of

Criminal Procedure. 4 The Supreme Court has held that “in the context of Rule 16 ‘the defendant's

defense’ means the defendant’s response to the Government’s case in chief.” United States v.

Armstrong, 517 U.S. 456, 462 (1996) (quoting former Rule 16(a)(1)(C), which currently appears in

similar form at Rule 16(a)(1)(E)). The concept of a “defense” encompasses only “shield claims”

that “refute the Government’s arguments that the defendant committed the crime charged.” Id.; see also

United States v. Nobles, 422 U.S. 225, 235–236 (1975) (“Both the language and history of Rule

16 indicate that it addresses only pretrial discovery.”). Sentencing proceedings do not involve the

question of whether the defendant committed a crime charged. As such, Rule 16 does not apply to

sentencing proceedings and therefore does not require the Government to disclose the evidence at issue

here. See United States v. Arditti, 955 F.2d 331, 345 (5th Cir. 1992) (holding that Rule 16 only applies

to evidence prior to trial); see also United States v. Liang, No. 4:17-CR-00001, 2021 WL 5323570, *2

4
Defs.’ Mot. Compel 7, Doc. 329-1.
Case 4:24-cr-00287-O Document 348 Filed 11/14/25 Page 4 of 5 PageID 8634

(E.D. Tex. Nov. 16, 2021) (“Rule 16 is not applicable in this case because Defendant’s request arises

post-conviction.”).

B. The Government’s Discovery Obligations Under Brady and Giglio

Defendants also seek to compel discovery under Brady and Giglio, arguing that the evidence

should have been produced in advance of Reis’s plea negotiations and Hockridge’s trial. 5 The

Government responds that “the [G]overnment team does not have possession, custody, or control of the

materials that Defendants request.” 6 Defendants argue that the Government has an obligation to obtain

and review potential Brady materials from other federal districts and specifically the District of Oregon. 7

The Court declines to extend the Government’s discovery obligations to other federal districts for Brady

and Giglio purposes.

The extent to which the “government team” includes individuals or agencies beyond the

prosecutors themselves depends on a “case-by-case analysis of the extent of interaction and cooperation

between” those individuals or agencies and the prosecutors pursuant to agency law. Avila v. Quarterman,

560 F.3d 299, 308 (5th Cir. 2009) (quoting United States v. Antone, 603 F.2d 566, 570 (5th

Cir.1979)). “[I]f a member of the government team has knowledge of Brady material, such knowledge

is imputed to the prosecutors.” Id. at 307 (citing Antone, 603 F.2d at 569). That said, “there are limits on

the imputation of knowledge from one arm of the government to prosecutors.” United States v. Webster,

392 F.3d 787, 798 n.20 (5th Cir. 2004). The government is deemed to have constructive knowledge only

if the information in question is “readily available to it.” Williams v. Whitley, 940 F.2d 132, 133 (5th

Cir. 1991) (emphasis added).

Here, Defendants have not adequately demonstrated the requisite “interaction and cooperation”

between the Government and the District of Oregon nor that the Government possess constructive

5
Id.
6
Gov.’s Res. To Defs.’s Mot Compel 2, Doc. 332-1.
7
Defs.’ Reply 2, Doc. 335-1.
Case 4:24-cr-00287-O Document 348 Filed 11/14/25 Page 5 of 5 PageID 8635

knowledge of the evidence in question. The Government avers that it had “limited interaction” with the

District of Oregon prior to the indictment and arrest of Eric and Anthony Karnezis. 8 Subsequently, the

Government conducted half of its interviews of Eric Karnezis and Anthony Karnezis with the District of

Oregon. Beyond these shared interviews, the Government “requested and produced discovery from the

investigative files given to it by the District of Oregon, which separately investigated and prosecuted

Eric and Anthony Karnezis, among others.” 9

Given that the Government has produced all the materials already received from the District of

Oregon, the limited interactions described above do not render the District of Oregon part of the

“government team” for Brady purposes. Neither are the District of Oregon’s remaining investigative

files considered “readily available” to the Government. See Williams, 940 F.2d at 133; see also United

States v. Esteves, No. 24-30336, 2025 WL 1912748, *4 (5th Cir. July 11, 2025) (holding that the

government team not having physical access to a recording at the county detention center and not having

listened to the recording, put it beyond the government’s reach for Brady purposes). As alleged, these

facts do not create an obligation for the Government to go looking for evidence it does not have in its

possession.

III. CONCLUSION

For the foregoing reasons Defendants’ Joint Motion to Compel Discovery is DENIED.

Additionally, Defendants’ Request for Hearing on Defendant’s Joint Motion to Compel Discovery (Doc.

330) is DENIED as moot. The parties’ motions to file Docs. 329, 332, and 335 and the accompanying

attachments under seal are GRANTED.

SO ORDERED this 14th day of November, 2025.

8
Gov.’s Res. To Dfs.’s Mot Compel 4 n.3, Doc. 332-1.
9
Gov.’s Res. To Dfs.’s Mot Compel 3-4, Doc. 332-1 (emphasis added).

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