RESPONSE to Standing Discovery Order by USA as to Eric Dean Sheppard Eleventh — Eric Dean Sheppard (Dkt. 117)

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Case 1:22-cr-20290-BB Document 117 Entered on FLSD Docket 10/10/2023 Page 1 of 2




                           UNITED STATES DISTRICT COURT
                           SOUTHERN DISTRICT OF FLORIDA

                             CASE NO. 22-20290-CR-BLOOM(s)

 UNITED STATES OF AMERICA,

 v.

 ERIC DEAN SHEPPARD,

            Defendant.
 __________________________________________________/

                      GOVERNMENT=S ELEVENTH RESPONSE TO
                        THE STANDING DISCOVERY ORDER

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

 This response also complies with Local Rule 88.10 and Federal Rule of Criminal Procedure 16.

 A.     5. The following records are being produced, or were previously produced via email and
        are being resent:

        Records from N.C.;
        IRS records;
        Documents provided by J.G.;
        Lease agreement;
        Deeds for shopping mall;
        Shopping mall photographs;
        Additional records located by Truist.


 B.     DEMAND FOR RECIPROCAL DISCOVERY: Pursuant to the Standing Discovery
          Order, the United States requests the disclosure and production of materials listed
          in Section (b) of Local Rule 88.10. This request is also made pursuant to Rule
          16(b) of the Federal Rules of Criminal Procedure.

        The government reiterates its request for reciprocal discovery of materials the defense
        intends to introduce at trial in its case in chief.


        The government is 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.


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Case 1:22-cr-20290-BB Document 117 Entered on FLSD Docket 10/10/2023 Page 2 of 2




      The government has produced the above-referenced documents bates numbered as
 SHEPP_034540 through SHEPP_034701, electronically via the USAFX portal.


                                            Respectfully submitted,

                                            MARKENZY LAPOINTE
                                            UNITED STATES ATTORNEY


                                      By:   s/Aimee Jimenez___________
                                            Aimee C. Jimenez
                                            Assistant United States Attorney
                                            Court No. A5500795
                                            99 Northeast 4th Street
                                            Miami, Florida 33132-2111
                                            Tel: (305) 961-9028
                                            Email: aimee.jimenez@usdoj.gov




                              CERTIFICATE OF SERVICE

        I HEREBY CERTIFY that on October 10, 2023, I electronically filed the foregoing
 document with the Clerk of the Court using CM/ECF (without attachments), which will send
 Notices of Electronic Filing to all counsel of record.



                                            s/Aimee Jimenez____________
                                            Aimee C. Jimenez
                                            Assistant United States Attorney




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