Ninth RESPONSE to Standing Discovery Order by USA as to Eric Dean Sheppard — Eric Dean Sheppard (Dkt. 80)

Summary

The Government's Ninth Response to the Standing Discovery Order, Document 80, entered on the FLSD docket 09/15/2023, in United States of America v. Eric Dean Sheppard, Case No. 22-20290-CR-BLOOM(s), in the United States District Court, Southern District of Florida. The government says it is producing additional Nationwide Lending Direct records received the evening of September 14, 2023 and one additional IRS certified record for HM Four, LLC, Bates numbered SHEPP_034206 through SHEPP_034442. It reiterates its demand for reciprocal discovery. The response is signed by Assistant United States Attorney Aimee C. Jimenez and dated through a certificate of service of September 15, 2023.

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Case 1:22-cr-20290-BB Document 80 Entered on FLSD Docket 09/15/2023 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 NINTH RESPONSE TO
                                THE STANDING DISCOVERY ORDER

          The United States hereby files this ninth 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:

          Additional Nationwide Lending Direct records received the evening of September 14,
          2023;
          One additional IRS certified record for HM Four, 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.


        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 has produced the above-referenced documents bates numbered as
 SHEPP_034206 through SHEPP_034442, electronically via the USAFX portal.




                                                       1
Case 1:22-cr-20290-BB Document 80 Entered on FLSD Docket 09/15/2023 Page 2 of 2




                                            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 15, 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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