Fourth RESPONSE to Standing Discovery Order by USA as to Dustin Sean McCabe — Dustin Sean Mccabe (Dkt. 45)

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Case 9:24-cr-80103-AMC Document 45 Entered on FLSD Docket 01/25/2025 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 FOURTH RESPONSE TO STANDING DISCOVERY ORDER

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

  (“SDO”), incorporating by reference its previous SDO responses. See DE 19; DE 25; DE 36.

  Since filing the Third SDO Response, the Government produced the following records via email

  on January 25, 2025: (1) messages between J.H. and J.M., marked as Bates MCCABE_ 003253

  through 003263, and (2) messages between D.A. and the Defendant, marked as Bates

  MCCABE_003264 through 003283. 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.

                                               Respectfully submitted,

                                               MICHAEL S. DAVIS
                                               ACTING UNITED STATES ATTORNEY

  Date: January 25, 2025                    By: /s/ Zachary A. Keller
                                               ZACHARY A. KELLER
                                               Assistant United States Attorney
                                               U.S. Attorney’s Office – SDFL
                                               Court No: A5502767
Case 9:24-cr-80103-AMC Document 45 Entered on FLSD Docket 01/25/2025 Page 2 of 2




                                           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 25, 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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