Fifth RESPONSE to Standing Discovery Order by USA as to Eric Dean Sheppard — Eric Dean Sheppard (Dkt. 48)

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Case 1:22-cr-20290-BB Document 48 Entered on FLSD Docket 07/06/2023 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 FIFTH RESPONSE TO
                                THE STANDING DISCOVERY ORDER

          The United States hereby files this fifth 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:

          Interview reports
          Copies of deeds for HM-UP Development Alafaya Trails, LLC


 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.

 N.       The government is disclosing the following information regarding the testimony of an
          expert witness:

                  The United States expects to rely on the testimony of a witness from the Internal
          Revenue Service with expertise in employer tax withholdings of employee wages and the
          difference between W-2 employees and Form 1099 independent contractors. The
          government will produce the curriculum vitae of the witness as soon as it is available.

        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 48 Entered on FLSD Docket 07/06/2023 Page 2 of 2




      The government is producing the above-referenced documents bates numbered as
 SHEPP_031285 – SHEPP_031324, 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 July 6, 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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