Fourth RESPONSE to Standing Discovery Order by USA as to Eric Dean Sheppard — Eric Dean Sheppard (Dkt. 47)

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Case 1:22-cr-20290-BB Document 47 Entered on FLSD Docket 06/09/2023 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 FOURTH RESPONSE TO
                          THE STANDING DISCOVERY ORDER

        The United States hereby files this fourth 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 documents are being produced:

        Florida Department of Revenue records;
        Bank of America records;
        Additional Paypal/Webbank records;
        Interview reports;
        SBA records;
        Copy of death certificate.


        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 a thumb drive containing the above-referenced documents
 bates numbered as SHEPP_011525 – SHEPP_031284.

        Previously, by letter dated August 2, 2022, the government advised counsel for the
 defendant that it had other documents unrelated to the charged conduct that it was making available

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Case 1:22-cr-20290-BB Document 47 Entered on FLSD Docket 06/09/2023 Page 2 of 2




 for inspection. On April 25, 2023, the government produced to defense counsel a copy of the
 following records that it had made available for inspection: records from AmeriAsia Bank, Bank
 United, Bank of America, City National Bank, Intercredit Bank, Key Bank, Suntrust Bank, and
 Wells Fargo; IRS records; Florida Division of Corporations records; and deposition transcripts.


                                               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 June 9, 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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