govinfo:USCOURTS-gand-1_25-cr-00079-1

IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA, 
 
 v. 
 
 CRIMINAL ACTION NO. 
 1:25-cr-00079-TRJ-JEM-6 
RANDALL L. CHUMLEY 
 
 
ORDER 
On February 19, 2026, the Magistrate Judge recommended that Defendant 
Randall L. Chumley’s motions for a bill of particulars (Doc. 78) and for disclosure of 
confidential informants (Doc. 80) be denied. (Doc. 126). Defendant filed timely 
objections on March 27, 2026. (Doc. 133). After a de novo review of the specific 
objections raised, Defendant’s objections are OVERRULED. 
BACKGROUND 
Defendant was charged with one count of wire fraud in connection with a 
scheme to obtain unemployment benefits from the Georgia Department of Labor. 
(Doc. 1). Defendant filed a motion for a bill of particulars which sought (1) the date 
and substance of all statements and actions he took that support the allegation he 
intended to defraud the Department of Labor; (2) the names of any alleged 
conspirators with whom he collaborated; and (3) any documents that support the 
allegations against him. (Doc. 78). Defendant filed a separate motion for disclosure of 
any confidential informants and any deals involving any cooperating source or 
potential witness. (Doc. 80). 
As to the bill of particulars, the Magistrate Judge determined that Defendant’s 

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“assertions that he has sufficient discovery now to properly prepare his defense” 
mooted the motion. (Doc. 126 at 6). The Magistrate Judge nonetheless ordered the 
government to produce any additional unproduced discovery immediately and 
reminded the govern ment of its obligations to disclose Brady and Giglio materials. 
(Id.) As to the disclosure of confidential informants, the Magistrate Judge reminded 
the government of its disclosure obligations as to any confidential informants it 
intends to call at trial, and the Magistrate Judge found that Defendant had not met 
his burden under Roviaro to compel the disclosure of informants the government did 
not intend to call. (Id. at 7–10). The Magistrate Judge also recommended the denial 
of Defendant’s request for disclosure within 45 days of trial of “all exculpatory 
evidence regarding every witness the government might call.” ( Id. at 10 –12). The 
Magistrate Judge reasoned that early disclosure was not warranted, and Defendant 
was not entitled to a witness list from the government. (
Id.) 
DISCUSSION 
In reviewing a Magistrate Judge’s report and recommendation (“R&R”), the 
district court “shall make a de novo determination of those portions of the report or 
specified proposed findings or recommendations to which the objection is made.” 28 
U.S.C. § 636(b)(1). A party objecting to an R&R “must specifically identify those 
findings objected to. Frivolous, conclusive, or general objections need not be 
considered by the district court.” 
United States v. Schultz, 565 F.3d 1353, 1361 (11th 
Cir. 2009) (quoting Marsden v. Moore, 847 F.2d 1536, 1548 (11th Cir. 1988)) (citation 
modified). If there are no specific objections made to factual findings made by the 

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magistrate judge, there is no requirement that those findings be reviewed de novo. 
Garvey v. Vaughn , 993 F.2d 776, 779 n.9 (11th Cir. 1993). The district judge “may 
accept, reject, or modify, in whole or in part, the findings or recommendations made 
by the magistrate judge,” 28 U.S.C. § 636(b)(1)(C), and may accept the 
recommendation if it is not clearly erroneous or contrary to the law. F ED. R. CIV. P. 
72(b)(3). Defendant raises two specific objections to the R&R. 
Defendant argues that the Magistrate Judge’s finding that Defendant’s motion 
for a bill of particulars was moot was error because there is still a concern that the 
government has not produced all of the discoverable material that has or may come 
to the government’s attention. (Doc. 133 at 2–3). But Defendant’s concern with “after-
arising discoverable material” is not consistent with a need for a bill of particulars. 
“The purpose of a bill of particulars is to inform the defendant of the charge in 
sufficient detail to enable adequate defense preparation and to minimize surprise at 
trial.” United States v. Colson, 662 F.2d 1389, 1391 (11th Cir. 1981). Defendant does 
not object that he is unable to ascertain the charges against him or prepare a defense. 
Instead, he asks for a preemptive order from the Court in the event the government 
discovers information not currently known to it and require a bill of particulars in the 
interim. (Doc. 133 at 3 (seeking a bill of particulars “pending receipt of that 
discovery.”)). A bill of particulars is not a “carte blanche to the defense to investigate 
the government’s case,” nor is it a discovery motion. 
United States v. Thevis, 474 F. 
Supp. 117, 123 (N.D. Ga. 1979). The government is aware of its ongoing obligations 

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to provide discoverable material to the defense, including Brady and Giglio material.1 
Defendant has not demonstrated that a bill of particulars is necessary to supplement 
that obligation. Defendant’s objection as to his motion for a bill of particulars is, 
therefore, OVERRULED. 
As to his request for disclosure of confidential informants, Defendant argues 
the Magistrate Judge erred by failing to (1) direct the government to comply with its 
promise to disclose the identity of an initial source and Brady/Giglio material related 
to that informant at least 30 days before trial, and (2) direct the government to 
otherwise provide Brady/Giglio material 20 to 30 days before trial. (Doc. 133). 
Defendant argues that these two requests were contained in his reply brief, but the 
Magistrate Judge did not address either request in the R&R. ( Id.) While it is true 
that the Magistrate Judge did not grant these requests , the Court finds no error in 
the omission. First, as the Magistrate Judge noted in the R&R, the Court’s 
Scheduling Order already requires the government to disclose Brady, Giglio, and 
Jencks material, and the Magistrate Judge found that Defendant had not shown good 
cause for early disclosure of such materials. (Doc. 17; Doc. 126 at 11–12). Defendant 
has not articulated a compelling reason for imposing a 20 to 30 day deadline for such 
disclosures in this case, and it was not error for the Magistrate Judge to decline that 
request. See Whidden v. Roberts , No. 5:19 -CV-80-MCR/MJF, 2020 WL 6566961, at 
 
1 To the extent Defendant’s objection implies that the government has not 
complied with the Magistrate Judge’s order directing it to produce full Rule 16 
discovery to Defendant immediately, Defendant should notify the Court of such non-
compliance within five days of this Order. 

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*4 (N.D. Fla. July 28, 2020), report and recommendation adopted , No. 5:19CV80-
MCR/MJF, 2020 WL 6566322 (N.D. Fla. Nov. 9, 2020) (“Although there is no precise 
deadline for when the government is required to disclose Brady material, courts have 
held that Brady requires disclosure in time for its effective use at trial.”) (collecting 
cases). 
Second, as to the government’s promise to disclose informant -related 
information to Defendant, Defendant similarly has not articulated a reason for the 
Court to compel the government to do what it has already agreed to do . The 
government represented in writing to the Court that it agreed to make the disclosure, 
it is bound by that representation, and Defendant has not shown that the government 
has taken action that is inconsistent with its representation to the Court . As such, 
Defendant’s objections are OVERRULED. 
CONCLUSION 
After a de novo review, Defendant’s objections to the R&R (Doc. 133) are 
OVERRULED, and the Court ADOPTS the findings and conclusions in the R&R (Doc. 
126) as the opinion and order of the Court. Defendant’s motion s for a bill of 
particulars (Doc. 78) and for disclosure of confidential informants (Doc. 80) are 
DENIED. 
The Magistrate Judge has certified this case ready for trial. Accordingly, 
counsel for Defendant Randall L. Chumley is DIRECTED to notify the Court, on or 
before June 12, 2026, if a plea of guilty will be entered or if this case will proceed to 
trial. Counsel shall notify the Court by contacting Britney Rodgers, the Courtroom 

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Deputy, at Britney_Rodgers@gand.uscourts.gov. 
The Court finds that the ends of justice served by taking this action outweigh 
the interests of the public and Defendant to a speedy trial, specifically for the purpose 
of allowing Defendant necessary time to consult with counsel and consider any plea 
offers, or alternatively, to file any necessary motions in limine, and for the Court to 
consider any such motions. The additional time is excluded from May 2 2, 2026 to 
June 12, 2026, for purposes of the Speedy Trial Act. 18 U.S.C. § 3161(h)(7)(A). The 
Clerk is respectfully DIRECTED to submit this matter to the Court if a change of 
plea hearing or trial has not been scheduled on the docket by June 12, 2026. 
SO ORDERED, this 22nd day of May, 2026. 
 
 
______________________________ 
TIFFANY R. JOHNSON 
United States District Judge 

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