Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

UNITED STATES OF AMERICA

v.

RAYNALDO RIVERA ORTIZ JR.

NO. 3:22-CR-378-N

GOVERNMENT’S BRIEF IN OPPOSITION TO

DEFENDANT’S MOTION TO RECONSIDER ORDER OF DETENTION

The Court should deny defendant Raynaldo Rivera Ortiz Jr.’s (“Ortiz”) motion to 

reconsider Magistrate Judge Horan’s detention order. (Dkt. 28.) As the government will 

demonstrate in this filing and at the scheduled hearing, Ortiz—using his specialized 

medical knowledge—committed conscience-shocking, heinous crimes in which he 

indiscriminately poisoned patients at a medical center where he worked. The unique 

nature of this course of conduct demonstrates, almost all by itself, that Ortiz poses an 

intolerable risk to the public; a person who could both engineer and implement such a 

scheme—and evade detection for three months—should not be released. Moreover, he 

committed these crimes while he was supposed to be under close supervision and 

scrutiny due to multiple previous episodes of misconduct, strongly suggesting that 

conditions of release will not mitigate the risk Ortiz poses to the public. 

Far from a close or marginal case for detention, as incorrectly suggested in the 

defense motion, all four of the Section 3142(g) detention factors—including the

seriousness and nature of the offense conduct, the overwhelming weight of the evidence, 

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 1 of 16 PageID 194
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 2

Ortiz’s long and troubled personal and professional history, and the danger that Ortiz

poses to the community—weigh heavily in favor of pretrial detention. Because the 

pretrial detention standard is amply satisfied, the Court should decline to reconsider the 

detention order. 

BACKGROUND

I. Factual Background1

A. Ortiz’s Significant History of Personal and Professional Misconduct

Ortiz is an anesthesiologist who frequently provided medical services to surgical 

patients at Baylor Scott and White Surgicare North Dallas (“BSW North Dallas”). 

(Detention Hearing Transcript (“Tr.”) at 17.) 

In addition to domestic violence arrests in 1995 and 2014 that did not result in 

convictions, Ortiz had two emergency protective orders taken out against him by female 

companions—one in 2005 and one in 2015. (Detention Hearing Exhibits (“Hrg. Exs.”) 1, 

3.) Ortiz was also convicted by a jury in 2016 in Collin County of shooting his 

neighbor’s dog. (Tr. at 29-30.) As the state appellate opinion recounts, Ortiz shot the

dog around the time of a domestic incident in which his neighbor assisted Ortiz’s

girlfriend in leaving Ortiz and testified against him at a protective-order hearing. (Id.; 

Hrg. Ex. 2)

Ortiz also has a disciplinary history both with the Texas Medical Board and with 

medical facilities at which he has been employed. (Hrg. Exs. 1, 3, 4.) In November 

1 Additional factual information will be presented at the hearing the Court has set in this matter 

for Friday, November 18, 2022.

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 2 of 16 PageID 195
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 3

2020, Ortiz was the anesthesiologist for a procedure Baylor Scott and White Surgicare 

North Garland (“BSW North Garland”), during which the patient suffered serious 

complications during anesthesia. (Id.; Tr. at 32-33.) In April 2021, in lieu of having his 

privileges revoked by BSW North Garland, Ortiz relinquished his medical staff 

membership and all clinical privileges at BSW North Garland. (Id.)

On August 19, 2022, Ortiz entered into an agreed order with the Texas Medical 

Board related to the November 2020 incident at BSW North Garland. (Tr. at 32-33.) 

The Texas Medical Board found that Ortiz “did not respond to the patient’s issues in an 

appropriate manner,” “failed to document the critical events,” and “did not recognize the 

patient’s inadequate oxygenation and ventilation.” (Hrg. Ex. 4.) Ortiz agreed to several

conditions, including submitting to extensive ongoing monitoring by a Board-selected 

physician at Ortiz’s expense, re-taking a Medical Jurisprudence Examination given by the 

Texas Medical Board, completing 16 hours of continuing medical education credits, and 

paying a penalty of $3,000. (Hrg. Ex. 4.)

Yet another critical medical incident involving Ortiz occurred while the Texas 

Medical Board was considering the discipline discussed above. (Tr. at 17-18.) 

Specifically, in an incident on or around May 19, 2022, a BSW North Dallas patient, 

G.A., stopped breathing under Ortiz’s care during a routine procedure. (Id.) The incident 

was under investigation at BSW North Dallas, and Ortiz expressed his dissatisfaction 

with the investigation to fellow staff. (Id. at 18.)

Ortiz failed to report these incidents to various institutions he worked for, despite 

obligations to do so. For example, Ortiz failed to notify Baylor Scott and White Medical 

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 3 of 16 PageID 196
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 4

Center – Garland of his criminal charges. (E.g., Hrg. Ex. 1.) Ortiz also failed to notify 

the Dallas Regional Medical Center—another facility where Ortiz did substantial 

amounts of work—of the Texas Medical Board investigation related to the November 

2020 North Garland incident.

Additionally, Ortiz has engaged in multiple incidents of erratic and hostile

workplace behavior. Ortiz engaged in multiple intense verbal altercations with surgical 

center staff at the Dallas Regional Medical Center—one of which became physical. 

(E.g., Tr. at 28-29.) During one episode, Ortiz injected anesthesia drugs into a patient 

while he knew that security personnel were attempting to remove him. (Id.) Due to these 

events, among others, Ortiz has a poor reputation among staff at several of the facilities at 

which he works, and witnesses expressed concerns about Ortiz retaliating against them if 

they cooperated with this investigation. (Id. at 28, 104.)

B. Ortiz Used His Specialized Knowledge to Cause the Death of a Fellow 

Doctor and a String of Severe Patient Injuries

M.K. was a doctor who worked at BSW North Dallas. On June 21, 2022, M.K. 

was at home treating herself for dehydration using an IV bag that investigators believe 

she had obtained from BSW North Dallas. (Tr. at 13.) Minutes after the IV bag was 

attached to M.K. intravenously, she experienced a major medical event and died before 

emergency medical personnel arrived on the scene. The medical examiner concluded 

that M.K. died of bupivacaine toxicity, and bupivacaine was found in her bloodstream. 

(Tr. at 13-14.) Bupivacaine solution is stocked at BSW North Dallas. (Id. at 12-13.)

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 4 of 16 PageID 197
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 5

On August 24, 2022, J.A., an 18-year-old male, was at BSW North Dallas for a 

surgery. During the surgery, unexpected complications arose when J.A. experienced a 

cardiac emergency. (Id. at 6-7.) J.A. was transferred to an emergency medical facility. 

(Id.) Physical inspection of the two suspected compromised IV bags found in BSW 

North Dallas’s warmer (a device that increases the temperature of an IV bag to prepare it 

for use during surgery) following J.A.’s emergency medical event showed evidence of 

tampering, with small puncture holes in the clear plastic packaging that encase the IV 

bags. (Id. at 7-9.)

Scientists at the University of North Texas performed chemical testing of the IV 

fluid from the IV bag that was attached to J.A.’s arm when the adverse event began 

occurring. (Id. at 8-10.) That testing confirmed the presence in the IV bag of 

epinephrine, a pharmaceutical stimulant that could easily have caused the cardiac 

symptoms J.A. experienced if it had been administered intravenously. (Id.) The fluid in 

the IV bag also tested positive for bupivacaine and lidocaine. (Id.) The IV bag not 

labeled to contain epinephrine, bupivacaine, or lidocaine. (Id.) 

After the incident involving J.A. and the autopsy report on M.K.’s death, BSW 

North Dallas personnel identified that the incidents involving J.A. and M.K. were likely 

not isolated and were likely part of a pattern of intentional adulteration of IV bags used 

for procedures at BSW North Dallas that caused cardiac emergencies. (Id. at 14.) BSW 

North Dallas personnel related that the incidents generally seemed to follow the same 

pattern in which a patient’s blood pressure would spike to dangerous levels at some point 

during the surgery, usually after the placement of additional IV bags—as opposed to the 

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 5 of 16 PageID 198
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 6

IV bag initially given the patient in the pre-operative process. (Id. at 14-17, 39.) BSW 

North Dallas personnel said that medical staff were able to save the lives of these patients 

by using the “crash cart”—a set of emergency tools used when complications arise during 

surgeries—and by transferring the patients to emergency medical facilities. (Id.)

Cardiovascular incidents fitting this pattern, and involving suspected compromised 

IV bags, occurred on or around July 7, 15, and 18; and August 1, 4, 9, and 19. (Hrg. Ex. 

5.) Ortiz was on vacation from on or around July 23 until on or around July 28, 2022. 

(Id.) No cardiovascular events occurred during the time he was on vacation, but the 

incidents started occurring again after he returned to BSW North Dallas from vacation on 

or around July 29, 2022; the first suspected incident thereafter occurred on or around 

August 1, 2022. (Id.)

C. Surveillance Footage Confirms Ortiz’s Involvement

Surveillance footage from BSW North Dallas’s operating room hallway strongly 

indicates Ortiz’s involvement in these events. (Id. at 21-22.) Surveillance footage exists 

dating from on or around August 2, 2022; the video in question was collected and 

reviewed by agents. (Id.)

Surveillance video shows that, on August 4, 2022 at or around 11:35 a.m., Ortiz

exited Operating Room 5 and walked toward the warmer with an IV bag in his hand. (Id. 

at 22-28.) In the footage, Ortiz walked slightly past the warmer, then turned and quickly 

placed the IV bag into the warmer. (Id.) After he placed the IV bag in the warmer, he 

looked both directions in the OR Hall and then quickly walked away. (Id.) At or around 

12:11 p.m., video shows a nurse obtaining an IV bag from the warmer for a surgery in 

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 6 of 16 PageID 199
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 7

Operating Room 1. (Id.) After that IV bag was placed, a cardiac event occurred and the 

patient was transferred to an emergency facility. (Id.)

On August 9, 2022, at or around 10:19 a.m., surveillance video shows Ortiz

exiting Operating Room 5 with an IV bag in his hand. (Id.) Ortiz walked to the warmer 

and quickly placed the IV bag in the warmer. (Id.) At or around 10:54 a.m., a staff 

member exited Operating Room 4 and retrieved an IV bag from the warmer. (Id.) 

Medical records reflect that a cardiac event occurred shortly thereafter in Operating 

Room 4, and the patient was transferred to an emergency facility. (Id.)

On August 19, 2022, at or around 10:34 a.m., surveillance video shows Ortiz

exiting Operating Room 5 with an IV bag hidden under what appears to be a paper folder. 

(Id.) Ortiz walked to the warmer and appeared to swap the IV bag under the paper folder 

for a different IV bag in the warmer. (Id.) At or around 10:42 a.m., a staff member 

exited Operating Room 2 and retrieved an IV bag from the warmer. (Id.) Medical 

records reflect that the IV bag was administered to a patient in Operating Room 2 at or 

around 10:45 a.m., and that the patient in Operating Room 2 experienced a cardiac event 

shortly thereafter. (Id.) Emergency measures were employed, and the patient was 

transferred to an emergency facility. (Id.) 

II. Procedural History

On September 13, 2022, Ortiz was charged by criminal complaint in the Northern 

District of Texas with Tampering With a Consumer Product (causing death and/or serious 

bodily injury) in violation of 18 U.S.C. § 1365(a), and felony drug adulteration charges 

under the Federal Food, Drug, and Cosmetic Act, 21 U.S.C. §§ 333(b)(7); 331(k); 351(d). 

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 7 of 16 PageID 200
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 8

Ortiz made his initial appearance on September 16, 2022, and the government moved to 

detain him pending trial. (Dkts. 3–4.) On October 5, 2022, Ortiz was subsequently 

indicted by a grand jury on five counts of tampering and five counts of adulteration. 

(Dkt. 17.)

Detention Hearing. On September 19, 2022, Ortiz appeared before Judge Horan 

for preliminary and detention hearings. (Dkt. 11.) The government called FDA-OCI 

Special Agent Daniel Allgeyer, who testified to, among other things, the facts above that 

are cited from the hearing transcript. See generally Tr. at 4-36. Magistrate Judge Horan 

entered an order of detention, finding that the government carried its burden of showing, 

by clear and convincing evidence, that Ortiz “poses a specific threat and danger to 

continue to engage in—or to, in the future, engage in—violent retaliatory behavior 

against those who are involved in this investigation, even if released on restrictive 

conditions.” (Dkt. 13 at 4.)

LEGAL STANDARDS

In reviewing a magistrate judge’s order of pretrial detention, this Court makes an 

“independent determination” on the issue of detention. United States v. Rueben, 974 F.2d 

580, 585 (5th Cir. 1992). The Court has discretion to supplement the magistrate judge’s 

decision “with additional findings based on its independent consideration of the record 

before the magistrate and the additional evidence adduced before it.” United States v. 

Fortna, 769 F.2d 243, 250 (5th Cir. 1985).

The Bail Reform Act of 1984 authorizes pretrial detention of a defendant without 

bail where “no condition or combination of conditions will reasonably assure the 

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 8 of 16 PageID 201
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 9

appearance of the person as required and the safety of any other person and the 

community.” 18 U.S.C. § 3142(e)(1). Detention is appropriate where a defendant is 

either a danger to the community or a flight risk; it is not necessary to prove both. See 

Fortna, 769 F.2d at 249. A finding that a defendant is a danger to the community must 

be supported by clear and convincing evidence. 18 U.S.C. § 3142(f)(2)(B). A finding 

that a defendant is a flight risk must be supported by a preponderance of the evidence. 

See United States v. Acosta-Leyva, 751 Fed. Appx. 594, 595 (5th Cir. 2019). 

The Court must consider four factors in determining whether the pretrial detention 

standard is met: (1) the nature and circumstances of the offense charged; (2) the weight of 

the evidence against the defendant; (3) the history and characteristics of the defendant, 

including the defendant’s past conduct, criminal history, and probation status; and (4) the 

nature and seriousness of the danger to any person or to the community that would be 

posed by the defendant’s release. 18 U.S.C. § 3142(g). 

ARGUMENT

All of the Section 3142(g) factors weigh heavily in favor of Ortiz’s detention. The 

nature and circumstances of the offense shock the conscience, the weight of the evidence 

is strong, and Ortiz’s personal characteristics amply illustrate the danger he poses to the 

community. Because there is no condition or combination of conditions that reasonably 

mitigate those risks, this Court should uphold Magistrate Judge Horan’s order and 

maintain Ortiz’s detention pending trial.

Nature and circumstances of the offense. The offenses charged here are heinous

public-safety crimes where Ortiz—a physician who presumably took an oath to do no 

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 9 of 16 PageID 202
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 10

harm—surreptitiously poisoned patients to the extent that life-saving measures were 

employed to stop them from dying. He did this repeatedly, inducing cardiovascular 

events with poisoned IV bags that he left in the IV bag warmer for his colleagues to use.

While the nature of the offense alone cannot be dispositive in this Court’s

detention determination, this factor overwhelmingly favors detention. Ortiz is an 

extraordinary danger to the public, and it is unclear what conditions could protect the 

public from the type of danger Ortiz poses if he were free. Surreptitiously poisoning IV 

bags was a novel way to commit a crime, and evidences remarkably depraved criminal 

creativity. Had Dr. Kaspar not unexpectedly taken a poisoned IV bag to her home and 

died, it is likely Ortiz would have evaded detection for far longer. The charges against 

Ortiz reflect that a dangerous person with extremely specialized knowledge who has 

access to dangerous substances can come up with novel ways to inflict harm. 

Weight of the evidence. The weight of the evidence against Ortiz is 

overwhelming. The defense motion incorrectly attempts to downplay the government’s 

case as built on “inferences.” (Dkt. 28 at 4.) But this ignores the fact that Ortiz was

caught red-handed on video inexplicably placing IV bags in the facility’s warmer minutes

before nurses took bags out of the exact same location—and then patients who were 

administered those bags experienced severe medical emergencies a short time after that. 

Being caught placing an instrumentality of a crime at the crime scene is direct evidence 

and does not require an “inference.” 

No one other than Ortiz placed random IV bags in the warmer with no logical 

explanation. No one other than Ortiz placed IV bags in the warmer directly before 

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 10 of 16 PageID 203
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 11

medical emergencies. No doctor had any reason to put IV bags into the warmer at all. 

Emergencies occurred only after bags were used from the warmer where Ortiz placed 

bags; cardiac emergencies did not occur when Ortiz did not place bags in the warmer. 

Furthermore, Ortiz’s remarkably furtive behavior surrounding his placement of the 

poisoned bags in the warmer speaks volumes. This is direct and persuasive evidence and 

logic, not “inferences.”

For his part, Ortiz doesn’t seem to disagree with large parts of the government’s 

case, having said that the government’s case is built on “partial truth” without describing 

what specific portion he believes is truthful. In a lengthy interview with the media

conducted last month in which Ortiz voluntarily participated, Ortiz seemed to agree that 

the cardiac incidents at the medical center were unusual. And Ortiz did not dispute the 

existence of poisoned IV bags. Instead, Ortiz offered a number of alternative

explanations for what happened at the center, most of which are contradictory and none 

of which actually explain what happened:

Ortiz’s Explanation Reality

People cannot inject drugs into folded, 

sealed IV bags.

People can inject drugs into folded, sealed 

IV bags.

Surveillance videos do not show Ortiz 

taking drugs out of the local anesthesia 

cabinet.

Surveillance videos show Ortiz taking 

drugs out of the local anesthesia cabinet, 

and such drugs were also available in the 

operating rooms.

Ortiz believes another doctor at the 

surgical center is a “sex maniac” and a 

pedophile.

The doctor he mentioned did not place IV 

bags in the warmer.

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 11 of 16 PageID 204
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 12

Interestingly, Ortiz’s motion does not offer these same explanations for the events 

at BSW North Dallas, but instead offers yet other explanations for the poisonings. None 

of those explanations fit the evidence either:

Motion Explanation Reality

“The surgical center experienced five 

incidents in 2021 in which patients from 

the center required emergency medical 

transports during a procedure . . . . [T]he 

government cannot exclude the possibility 

that the incidents began before the 

Defendant’s ostensible motive.” (Dkt. 28

at 4.)

The five emergency transfers in 2021 

were varied and of a different character 

than the poisonings that Ortiz committed. 

Typical anesthesia or surgical 

complications involve low blood pressure

or allergic reactions, not high blood 

pressure. 

“The crux of the government’s case, at 

least so far, is that Defendant put IV bags 

in a warmer, and some cardiac incidents 

have been linked to adulterated IV bags.” 

(Dkt. 28 at 4.)

Ortiz surreptitiously put an IV bag in the 

facility’s warmer, and came back in a 

furtive manner to “check” on a bag he just 

placed there; minutes later, a nurse took a 

bag from the same location; minutes after 

that, a patient experienced a medical 

emergency.

History and characteristics of the defendant. As noted above, Ortiz has a lengthy 

history of personal and professional misconduct including violence, as well as a criminal 

conviction that involves retaliating against a witness. The fact that Ortiz was under close 

scrutiny and supervision by regulators at the time of the current offense indicates both his 

likely inability to comply with conditions of release and his lack of respect for the law. 

Ortiz also has a troubling history of failing to report his misconduct to the facilities where 

he worked, which further underlines his likely inability to comply with conditions of 

release. 

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 12 of 16 PageID 205
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 13

Danger to any person or the community. Section 3142(g)(4) requires the court to 

consider not only the danger to the community but also “the nature and seriousness of the 

danger to any person . . . that would be posed by the person’s release.” The nature of the 

offense conduct, Ortiz’s criminal history, Ortiz’s medical expertise, and Ortiz’s history of 

surreptitious, retaliatory, and/or violent attacks make strikingly clear that Ortiz is a 

danger to the community and there are no conditions of release that reasonably mitigate 

that danger. 

Ortiz’s motion fails to grapple meaningfully with any of these issues, suggesting 

that his lack of a medical license makes Ortiz poisoning people “singularly unamenable 

to repetition.” (Dkt. 28 at 4.) But, of course, a medical license is not required to poison 

people or retaliate against witnesses—and Ortiz has proven that he is proficient at doing 

both. In terms of poisoning people, Ortiz has access through his business and his 

connections in the medical industry to the same or similar tools he used to commit his 

crime. Ortiz’s motion does not propose any conditions that could mitigate the risk that 

Ortiz will offend again using even more surreptitious means—because there are no such 

conditions.

And in terms of retaliating against witnesses, the defense motion incorrectly 

describes his conviction for shooting his neighbor’s dog as “not involv[ing] a human 

victim.” (Dkt. 28 at 4.) As an initial matter, the defense motion is wrong because 

shooting a person’s pet obviously victimizes the owner of the injured animal. But, more 

importantly, the defense motion gets it entirely backward. No one reading Judge Ada 

Brown’s opinion in Ortiz’s criminal case could miss what happened—Ortiz shot his 

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 13 of 16 PageID 206
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 14

neighbor’s dog after his neighbor helped Ortiz’s live-in girlfriend escape from Ortiz’s

acts of domestic violence and after his neighbor testified against Ortiz at a protective 

order hearing. Ortiz v. State, No. 05-16-00817-CR, 2018 WL 416495, at *5 (Tex. App. 

Jan. 16, 2018). There is no way to mitigate against the risk of Ortiz resuming and 

escalating these types of behaviors given his current situation, and the overwhelming 

evidence indicates that witnesses are fearful of what Ortiz will do upon release.

In sum, all four factors strongly favor detention. Ortiz’s crime and his history are 

too clearly dangerous and problematic to allow Ortiz the opportunity for mischief while 

awaiting trial. He should remain detained.

CONCLUSION

For the foregoing reasons, the Court should not reconsider or alter Magistrate 

Judge Horan’s detention order.

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 14 of 16 PageID 207
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 15

Respectfully submitted,

CHAD MEACHAM

ACTING UNITED STATES ATTORNEY

JOHN J. DE LA GARZA

Assistant United States Attorney

Texas State Bar No. 00796455

1100 Commerce Street, Suite 300

Dallas, Texas 75242

214-659-8838

s/ Patrick R. Runkle

PATRICK R. RUNKLE

Senior Litigation Counsel

Consumer Protection Branch

U.S. Department of Justice

P.O. Box 386

Washington, DC 20044-0386

202-532-4723

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 15 of 16 PageID 208
Government’s Brief in Opposition to 

Motion to Reconsider Detention Order—Page 16

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing will be served on counsel for the

defendant via electronic mail on the 16th day of November, 2022.

/s/ Patrick R. Runkle.

Patrick R. Runkle

Senior Litigation Counsel

Case 3:22-cr-00378-N Document 30 Filed 11/16/22 Page 16 of 16 PageID 209