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`HICKEY & CHUNG, LLP
`Naomi Chung (SBN 283743)
`Brendan Hickey (SBN 261794)
` chung@defender.law
` hickey@defender.law
`Pier 9, Suite 100
`San Francisco, CA 94111
`T: (415) 942-9000
`F: (415) 484-7054
`
`TAMARA CREPET LAW
`Tamara A. Crepet (SBN 277408)
`Pier 9, Suite 100
`San Francisco, CA 94111
`T: (415) 517-3496
`
`Attorneys for Defendant
`DAVID BRODY
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`SAN FRANCISCO DIVISION
`
`
`UNITED STATES OF AMERICA,
`
`Plaintiff,
` v.
`DAVID BRODY,
`
`
`
`
`Defendant.
`
`Case No. 24-CR-329-CRB-2
`
`DEFENDANT DAVID BRODY’S STATUS
`REPORT
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`On February 7, 2025, this Court held a hearing regarding the filter team’s production of
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`potentially privileged material. Dr. Brody raised a concern that he was unable to access documents
`belonging to Done Health, P.C. which had been deemed privileged by counsel for Done Global, Inc.
`(“Done Health Privileged Material”). As the sole owner and director of Done Health, P.C., Dr. Brody
`asserted that he was entitled access to the documents under the terms of the Management Services
`
`STATUS REPORT
`BRODY, CR 24–329-CRB
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`Case 3:24-cr-00329-CRB Document 228 Filed 02/21/25 Page 2 of 2
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`Agreement (“MSA”) between Done Health, P.C. and Done Global, Inc.1 In response the Court directed
`counsel for Dr. Brody to file a motion to compel the filter team to produce the relevant documents.
`
`Since the hearing, counsel for both defendants and Done Global, Inc., have met and conferred and
`reached an agreement for disclosure of the relevant documents. Done Global, Inc. has agreed to make
`available all privileged documents related to the operations of Done Health, P.C. pursuant to the terms of
`the MSA. This includes all documents that reference Dr. Brody. In turn, Dr. Brody has agreed to
`maintain the confidentiality of Done Health Privileged Material and to refrain from any disclosures of
`those documents that would result in a waiver or loss of any privilege or confidentiality right otherwise
`available without either the prior written consent of Done Global, Inc. and Done Health, P.C., or prior
`authorization by the Court. Dr. Brody further agrees to meet and confer with Done Global, Inc. and Ms.
`He before moving the Court for authorization to disclose any Done Health Privileged Material. It is
`anticipated that it will take several weeks for this material to be produced to Dr. Brody.
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`In light of the above, Dr. Brody will not need to file a motion to compel disclosure of Done
`Health Privileged Material.
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` Dated: February 21, 2025
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`By:
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`Respectfully submitted,
`
`HICKEY & CHUNG LLP
`TAMARA CREPET LAW
`
`______/s/___________
`Naomi Chung
`Brendan Hickey
`Tamara Crepet
`
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`
`
`Attorneys for Defendant
`DAVID BRODY
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`1 At the time the Management Services Agreement was signed, on August 10, 2020, Done Global, Inc.
`was named Okay Health, Inc. On April 16, 2021, Ms. He amended Okay Health, Inc.’s name and
`changed it to Done Global, Inc.
`STATUS REPORT
`BRODY, CR 24–329-CRB
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