Second RESPONSE to Standing Discovery Order by USA as to Eric Dean Sheppard — Eric Dean Sheppard (Dkt. 29)

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Case 1:22-cr-20290-BB Document 29 Entered on FLSD Docket 08/19/2022 Page 1 of 2




                         UNITED STATES DISTRICT COURT
                         SOUTHERN DISTRICT OF FLORIDA
                     CASE NO. 22-20290-CR-BLOOM/OTAZO-REYES

 UNITED STATES OF AMERICA,

 v.

 ERIC DEAN SHEPPARD,

               Defendant.
 ________                          /

                        GOVERNMENT=S SECOND RESPONSE TO
                         THE STANDING DISCOVERY ORDER

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

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

        A.             Books, papers, documents, data, photographs, tangible objects, buildings or
                       places, within the government’s possession, custody or control, which are
                       material to the preparation of the defendant’s defense, or which the
                       government intends to use as evidence at trial to prove its case in chief, or
                       which were obtained from or belong to the defendant, may be inspected at
                       a mutually convenient time at: the Office of the United States Attorney, 99
                       Northeast 4th Street, Miami, Florida, Suite 4000. Please call the
                       undersigned to set up a date and time that is convenient to both parties.

                       The attachments to this discovery response are not necessarily copies of all
                       the books, papers, documents, data, etc., that the government may intend to
                       introduce at trial.

        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 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.

        The Government is producing via email a zip file containing documents bates numbered
 as SHEPP_010357 – SHEPP_010546. Please contact the undersigned Assistant United States
 Attorney if any pages are missing.


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Case 1:22-cr-20290-BB Document 29 Entered on FLSD Docket 08/19/2022 Page 2 of 2




                                               Respectfully submitted,

                                               JUAN ANTONIO GONZALEZ
                                               UNITED STATES ATTORNEY



                                         By:    /s Marty Fulgueira Elfenbein______
                                               MARTY FULGUEIRA ELFENBEIN
                                               Assistant United States Attorney
                                               Florida Bar No. 0020891
                                               99 Northeast 4th Street
                                               Miami, Florida 33132-2111
                                               Tel: (305) 961-9112
                                               Email: Marta.Elfenbein@usdoj.gov




                                CERTIFICATE OF SERVICE

          I HEREBY CERTIFY that on August 19, 2022, I electronically filed the foregoing
 document with the Clerk of the Court using CM/ECF, which will send Notices of Electronic Filing
 to all counsel of record.


                                                    /s Marty Fulgueira Elfenbein_________
                                                    MARTY FULGUEIRA ELFENBEIN
                                                    Assistant United States Attorney




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