Unopposed Motion for Protective Order — No. 3:26-cr-00205 (Dkt. 11, D. Or.)

Summary

Unopposed Motion for Protective Order, Document 11 in Case 3:26-cr-00205-AN-01 in the District of Oregon, Portland Division, filed 06/11/26 and dated June 11, 2026 for the United States Attorney. The government asks the Court to limit copying and dissemination of discovery that contains highly sensitive personal and financial information, explaining that the volume of material and the frequency of sensitive data make redaction infeasible. The proposed order would bar defence counsel from giving the defendant copies containing personal identifying information such as dates of birth, Social Security numbers and addresses, or financial information such as account numbers, statements and tax return data, unless redacted or the defendant's own, and would bar sharing discovery with anyone not involved in the case without written permission. Defence counsel does not object.

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       Case 3:26-cr-00205-AN           Document 11        Filed 06/11/26      Page 1 of 3




SCOTT E. BRADFORD, OSB #062824
United States Attorney
District of Oregon
CHRISTOPHER L. CARDANI, MA #550609
MEREDITH D.M. BATEMAN, OSB #192273
Assistant United States Attorneys
christopher.cardani@usdoj.gov
meredith.bateman@usdoj.gov
1000 SW Third Avenue, Suite 600
Portland, OR 97204-2902
Telephone: (503) 727-1000
Attorneys for United States of America




                            UNITED STATES DISTRICT COURT

                                   DISTRICT OF OREGON

                                    PORTLAND DIVISION


 UNITED STATES OF AMERICA                            3:26-cr-00205-AN-01

                v.                                   UNOPPOSED MOTION FOR
                                                     PROTECTIVE ORDER
 DAVID STARLING,

                Defendant.


       The United States of America respectfully moves this Court for a protective order

limiting the copying and dissemination of certain materials set forth below. Defendant’s counsel

does not object to this motion. In the interest of providing timely discovery to the defendant, the

government respectfully requests that the Court enter the accompanying order.

       The discovery material in the case includes highly sensitive information, including

personal and financial information. Due to the large volume of discovery material, the frequency


Unopposed Motion for a Protective Order                                                      Page 1
       Case 3:26-cr-00205-AN            Document 11         Filed 06/11/26       Page 2 of 3




with which the sensitive information appears throughout the documents, and the nature of the

violations charged in this case, redaction of all discovery is not a feasible option.

       As such, the government respectfully requests that the Court order that defendant’s

counsel shall not provide copies of the discovery material produced by the government to

defendant which contains personal identifying information or financial information, defined as

follows:

       (a)     Personal Information: personal identifying information of any individual,

including without limitation, any individual=s date of birth, social security number, address,

telephone number, email address, driver=s license number, professional license number, or family

members= names; or

       (b)     Financial Information: financial information of any individual or business,

including without limitation, bank account numbers, credit or debit card numbers, account

passwords, account names and contact information, account history, account balances, account

statements, tax return information, or taxpayer identification numbers,

unless defense counsel first redacts the Personal Information or Financial Information from the

discovery materials or if the Personal Information or Financial Information is the defendant’s

own information.

       The government further moves the Court to order that defendant’s counsel and defendant

neither share any discovery material produced by the government with others not involved in

case-related activities nor make any public disclosure of the same, without the government’s

express written permission, except that defense counsel may provide discovery materials to those

persons employed by defense counsel who are necessary to assist counsel for trial or other

proceedings.

Unopposed Motion for a Protective Order                                                        Page 2
       Case 3:26-cr-00205-AN           Document 11        Filed 06/11/26       Page 3 of 3




       These restrictions should not hinder defendant’s ability to prepare for trial and will

protect others from potential harassment or exposure to misuse of their personal and financial

information. Defense counsel is free to raise any issues regarding this protective order during the

course of this litigation should this order impact counsel’s representation of defendant.

       For the foregoing reasons, the government respectfully requests that the Court enter the

proposed Protective Order.

Dated: June 11, 2026                          Respectfully submitted,

                                              SCOTT E. BRADFORD
                                              United States Attorney

                                              /s/ Meredith D.M. Bateman
                                              CHRISTOPHER L. CARDANI, MA #550609
                                              MEREDITH D.M. BATEMAN, OSB #192273
                                              Assistant United States Attorneys




Unopposed Motion for a Protective Order                                                         Page 3


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