Third RESPONSE to Standing Discovery Order by USA as to Dustin Sean McCabe — Dustin Sean Mccabe (Dkt. 36)

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Case 9:24-cr-80103-AMC Document 36 Entered on FLSD Docket 01/11/2025 Page 1 of 2




                             UNITED STATES DISTRICT COURT
                             SOUTHERN DISTRICT OF FLORIDA

                                CASE NO. 24-CR-80103-CANNON

  UNITED STATES OF AMERICA

  v.

  DUSTIN SEAN McCABE,

        Defendant.
  ____________________________________/

       GOVERNMENT=S THIRD RESPONSE TO STANDING DISCOVERY ORDER

         The United States hereby files this third response to the Standing Discovery Order

  (“SDO”), incorporating by reference its previous SDO responses. See DE 19; DE 25. Since filing

  the Second SDO Response, the Government produced the following records via email on

  January 2, 2025: (1) Coast Guard Investigative Service reports marked as Bates MCCABE_

  003250 through 003252, (2) Palm Beach County medical examiner records marked as Bates

  MCCABE_003186 through 003210 and 003248, (3) records from The Maritime Consortium,

  Inc., marked as Bates MCCCABE_003211 through 003220, (4) United States Coast Guard

  records marked as Bates MCCABE_003221 through 003247, (5) a PGA National Members Club

  membership record marked as Bates MCCABE_003249, and (6) global positioning system data

  produced as a native file with a filename beginning “Raw Data…”. Counsel for the defense

  should alert the undersigned Assistant United States Attorney if it has any problems accessing

  these records.

         The government remains aware of its continuing duty to disclose such newly discovered

  additional information required by the Standing Discovery Order, Rule 16(c) of the Federal

  Rules of Criminal Procedure, Brady, Giglio, Napue, and the obligation to assure a fair trial.
Case 9:24-cr-80103-AMC Document 36 Entered on FLSD Docket 01/11/2025 Page 2 of 2




                                           Respectfully submitted,

                                           MARKENZY LAPOINTE
                                           UNITED STATES ATTORNEY

  Date: January 11, 2025                By: /s/ Zachary A. Keller
                                           ZACHARY A. KELLER
                                           Assistant United States Attorney
                                           U.S. Attorney’s Office – SDFL
                                           Court No: A5502767
                                           99 NE 4th Street, 6th Floor
                                           Miami, Florida 33132
                                           Tel: (305) 961-9023
                                           Email: zachary.keller@usdoj.gov

                                   CERTIFICATE OF SERVICE

         I HEREBY CERTIFY that on January 11, 2025, I electronically filed the foregoing
  document with the Clerk of the Court using CM/ECF. I also certify that referenced discovery
  was served on counsel of record as described herein.

                                                  /s/ Zachary A. Keller
                                                  ZACHARY A. KELLER
                                                  Assistant United States Attorney




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