Motion for Entry of Protective Order – Page 1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

SHERMAN DIVISION 

UNITED STATES OF AMERICA § 

§ No. 4:23-CR-243 

v. § JUDGE ALM/AGD 

§ 

LASHONDA MOORE (01) § 

MARLON MOORE (02) § 

MOTION FOR ENTRY OF PROTECTIVE ORDER REGARDING DISCOVERY 

PURSUANT TO FED. R. CRIM. P. 16(d)(1) 

Pursuant to Federal Rule of Criminal Procedure 16(d) and 18 U.S.C. § 3771(a), 

the United States of America, by and through the undersigned, moves for the entry of a 

protective order regarding the dissemination of discovery and offense materials, and in 

support thereof states as follows: 

1. The defendants, LaShonda Moore and Marlon Moore, were charged on 

November 8, 2023, in a nine-count indictment with violations of 18 U.S.C. § 1349 

(Conspiracy to Commit Wire Fraud); 18 U.S.C. § 1343 (Wire Fraud), and 18 U.S.C. 

§ 1957 (Money Laundering). 

2. Pursuant to Federal Rule of Criminal Procedure 16, the Government 

intends to produce discovery material to defendants’ counsel. 

3. This discovery will include sensitive information, whose unrestricted 

dissemination could adversely affect law enforcement interests and the privacy interests 

of third parties. 

4. To protect the aforementioned interests, the Government requests that the 

Court enter an order of protection regarding the dissemination of the discovery. 

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Motion for Entry of Protective Order – Page 2

5. The Court’s authority to issue such an order is well established.

Specifically, Rule 16(d)(1) permits courts to enter protective orders that deny, restrict, or 

defer discovery or inspection, or grant other appropriate relief for good cause. Rule 

49.1(e) provides authority to issue protective orders concerning matters of privacy and 

personal information. Id. Indeed, “[a] trial court can and should, where appropriate, 

place a defendant and his counsel under enforceable orders against unwarranted 

disclosure of the materials which they may be entitled to inspect.” Alderman v. United 

States, 394 U.S. 165, 185 (1969). 

6. Accordingly, the Government requests this Court limit the disclosure of 

these documents, as specified in the proposed protective order.

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Motion for Entry of Protective Order – Page 3 

WHEREFORE the United States respectfully requests that the Court enter a 

protective order regarding the discovery materials in this case. 

Respectfully submitted, 

 GLENN S. LEON 

 FRAUD SECTION CHIEF 

/s/ Theodore M. Kneller 

 THEODORE M. KNELLER 

 Trial Attorney, Fraud Section 

 U.S. Department of Justice 

 D.C. Bar No. 978680 

1400 New York Ave., NW 

Washington, D.C. 20530-0001 

 (202) 514-5799 

 (202) 514-3708 (fax) 

 Theodore.Kneller@usdoj.gov 

CERTIFICATE OF SERVICE 

 I hereby certify that a copy of the foregoing Motion for Entry of Protective Order 

Pursuant to Fed. R. Crim. P. 16(d)(1) has been served on counsel of record for defendants 

via the court’s CM/ECF system on the 6th day of December 2023. 

/s/ Theodore M. Kneller 

 THEODORE M. KNELLER 

 Trial Attorney, Fraud Section 

CERTIFICATE OF CONFERENCE 

I hereby certify that I have conferred with counsel for the defendants regarding the 

merits of this motion, and they are unopposed to the granting of the motion. 

/s/ Theodore M. Kneller 

 THEODORE M. KNELLER 

 Trial Attorney, Fraud Section 

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