Sixth RESPONSE to Standing Discovery Order by USA as to Eric Dean Sheppard — Eric Dean Sheppard (Dkt. 66)

Summary

The Government's Sixth Response to the Standing Discovery Order, entered on the docket 09/01/2023 as Document 66 in United States of America v. Eric Dean Sheppard, Case No. 22-20290-CR-BLOOM(s) (docket No. 1:22-cr-20290-BB), in the U.S. District Court for the Southern District of Florida. The United States lists documents being produced, including certified copies of IRS records, records from ACAP SME, records from Burlington Coat Factory and Dick's Sporting Goods, a record from SBA re HM Four and additional PayPal records, Bates numbered SHEPP_031325 through SHEPP_032454. It reiterates its request for reciprocal discovery and states that it has disclosed information about its expert witness. The signature line reads s/Aimee Jimenez, Assistant United States Attorney, with a certificate of service dated September 1, 2023.

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Case 1:22-cr-20290-BB Document 66 Entered on FLSD Docket 09/01/2023 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 SIXTH RESPONSE TO
                          THE STANDING DISCOVERY ORDER

        The United States hereby files this sixth 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:

        Certified copies of IRS records previously produced, with one additional tax return for HM
        Up Development Alafaya Trails;
        Records from ACAP SME, which are the loan records previously produced from Northeast
        Bank, plus email records and log-in record;
        Records from Burlington Coat Factory and Dick’s Sporting Goods;
        Record from SBA re HM Four;
        Additional PayPal records;
        Record of no record from Truist Bank;
        DAVID record;
        Google, Yahoo and Breezeline records were previously produced.


 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 has disclosed information about its expert witness and has produced the
        witness’s curriculum vitae to the defense.


                                                1
Case 1:22-cr-20290-BB Document 66 Entered on FLSD Docket 09/01/2023 Page 2 of 2




        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 (or has produced) the above-referenced documents bates
 numbered as SHEPP_031325 through SHEPP_032454, 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 September 1, 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




                                                2


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