Sixth RESPONSE to Standing Discovery Order by USA as to Dustin Sean McCabe — Dustin Sean Mccabe (Dkt. 57)

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The Government's Sixth Response to Standing Discovery Order in United States of America v. Dustin Sean McCabe, Case No. 24 -80103-CR-CANNON, in the U.S. District Court for the Southern District of Florida, entered on the docket 02/18/2025 as Document 57. The United States incorporates its previous responses, DE 19, DE 25, DE 36, DE 45 and DE 51. It lists records produced via email and USAfx on February 17, 2025, including a photograph of C.M.'s dive logbook marked MCCABE_003303 and records from GEICO marked MCCABE_003308-003642, and supplemental reports marked MCCABE_003643-003646 produced on February 18, 2025. The signature line reads /s/ Zachary A. Keller, Assistant United States Attorney, dated February 18, 2025.

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Case 9:24-cr-80103-AMC Document 57 Entered on FLSD Docket 02/18/2025 Page 1 of 2




                               UNITED STATES DISTRICT COURT
                               SOUTHERN DISTRICT OF FLORIDA

                                 CASE NO. 24 -80103-CR-CANNON

  UNITED STATES OF AMERICA

  v.

  DUSTIN SEAN McCABE,

        Defendant.
  ____________________________________/

           GOVERNMENT=S SIXTH RESPONSE TO STANDING DISCOVERY ORDER

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

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

  45; DE 51. Since filing the Fifth SDO Response, the Government produced the following records

  via email and USAfx:

           On February 17, 2025, (1) a photograph of C.M.’s dive logbook marked as Bates

            MCCABE_003303, (2) screenshots of C.M.’s text messages with J.H. marked as Bates

            MCCABE_003304-003306,(3) reports from a witness preparation interview of C.H.

            marked as Bates MCCABE_03307, (4) records from GEICO marked as Bates

            MCCABE_003308-003642.

           On February 18, 2025, supplemental reports marked as Bates MCCABE_003643-

            003646.

            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,
Case 9:24-cr-80103-AMC Document 57 Entered on FLSD Docket 02/18/2025 Page 2 of 2




  and the obligation to assure a fair trial.

                                                  Respectfully submitted,

                                                  HAYDEN P. O’BYRNE
                                                  UNITED STATES ATTORNEY

  Date: February 18, 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 February 18, 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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