USA v. Reis et al

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
STEPHANIE HOCKRIDGE
(01)
(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.
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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.
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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.
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(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.
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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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