United States of America v. Paige et al

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
UNITED STATES OF AMERICA 	CIVIL ACTION
VERSUS 	NO. 25-2040
UNNISHA S. PAIGE, et al. 	SECTION M (4)
ORDER
On September 21, 2026, the United States Magistrate Judge issued a Report and
Recommendation (“R&R”) on the government’s motion for sanctions against defendant Unnisha
Paige arising from Paige’s violation of discovery orders. 1 	The R&R recommended that the
government’s motion be granted and that the government be awarded reasonable attorney’s fees
in the amount of $1,536.00. 2 	The R&R also recommended that this Court issue an adverse
inference against Paige finding that Paige exercised oversight over Paige Tax franchisees, received
income from them, and participated in the preparation of tax returns for customers that included
false information.3 	Objections to the R&R were due on or before October 5, 2026.4 	Paige did
not file an objection. 	However, codefendant Deshira J. Horton objected to the R&R and
“request[ed] an express limitation that any inference based on Unnisha S. Paige’s discovery
violations applies solely against Paige.” 5 	Specifically, Horton asks the Court to sustain her
objection and include the following limitation in any order adopting the adverse-inference
recommendation:
Any adverse inference adopted from the [R&R] concerning Paige’s oversight of
Paige Tax franchisees, receipts of income from them, or participation in preparing
returns containing false information applies solely against [d]efendant Unnisha S.
1 R. Doc. 121 (citing R. Doc. 107).
2 Id. at 5-8.
3 Id. at 3-5, 9.
4 Id. at 9.
5 R. Doc. 123 at 1. 	Horton states that she “takes no position on whether Paige should be sanctioned, on the
sanctions recommended against Paige, or on any award of attorney’s fees against Paige.” 	Id.
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Paige. 	It shall not be treated as an established fact, presumption, evidentiary
inference, or discovery sanction against [d]efendant Deshira J. Horton, and shall
not shift any burden to Horton. 	The inference does not resolve Horton’s
relationship or financial arrangements with Paige; the existence or degree of Paige’s
supervision or control over Horton; Horton’s knowledge of Paige’s or any other
defendant’s conduct; who prepared or participated in preparing any return
attributed to Horton; whether information on such a return was false; or Horton’s
knowledge, intent, willfulness, recklessness, or due diligence concerning that
information. 	Those matters remain subject to proof independently of Paige’s
sanction. 	This limitation applies at summary judgment, at trial, and in any other
merits determination concerning Horton. 	No party may invoke Paige’s sanction
as proof against Horton, and any presentation of the inference to the factfinder shall
expressly identify its application solely to Paige. 	Nothing in this limitation
excludes otherwise admissible evidence offered independently of the sanction.6
The Court ordered the government to provide its position on Horton’s objection and her
requested modification to the adverse-inference recommendation.7 	The government responded
that it does not oppose the adverse inference being limited to Paige.8 	But the government did not
address the specific language requested by Horton.9
Having considered the government’s motion for sanctions, the record, the applicable law,
the R&R, Horton’s objection to the R&R, and the government’s response, the Court hereby
approves the Report and Recommendation and adopts it as its opinion in this matter. 	The Court
notes, though, that the adverse-inference recommendation is limited to Paige and adopts in whole
the limitation articulated in Horton’s objection as quoted above. 	Therefore,
IT IS ORDERED that the government’s motion for sanctions against Paige (R. Doc. 107)
is GRANTED, and the government is awarded reasonable attorney’s fees in the amount of
$1,536.00.
IT IS FURTHER ORDERED that the Court issues an adverse inference against Paige
6 Id. at 4-5.
7 R. Doc. 124.
8 R. Doc. 126.
9 See id.
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finding that Paige exercised oversight over Paige Tax franchisees, received income from them,
and participated in the preparation of tax returns for customers that included false information.
IT IS FURTHER ORDERED that the adverse inference applies only to Paige and no other
defendant.
New Orleans, Louisiana, this 14th day of October, 2026.
_________________________________
BARRY W. ASHE
UNITED STATES DISTRICT JUDGE
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