Amber Bruey Discovery Letter — USA v. Bruey et al (Dkt. 37.1)

Record facts

U.S. District Court for the Middle District of Florida · No. 2:21-cr-00074 · Doc. 37-1 · 2021-09-28 · Docket on CourtListener

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2110 First Street, Suite 3-137
Fort Myers, Florida 33901
239/461-2200
239/461-2219 (Fax)
35 SE lstAvenue, Suite 300
Ocala,Fllorid.aS4ll
352/ 547-3600
3s2/547-3623 (Fax)
U.S. Department of Justice
arri te d S te tes Atto fite !
Middle District of Florida
Main Office
r()0 North Tampa Street, Suite 3200
Tampa, Florida 33602
813/274_6000
813/274-6358 (Fax)
300 N. Hogan Street, Suite 200
Jacksonville, Florita 32202
904/301_6300
9041301-6310 (Fax)
4)0 .West'Washington 
Street, Srdte 3100
Orlando, Florida 32801
N7 /648-7500
407/648-7643 (Fax\
Reply to: Fort Myers, FL
September 28,2021
Jim Lappan
2075 W. First Street, Suite 300
Fort Myers, Florida 33901
R:e: United States y, Amber Rewis Bruey
Case No. 2 :2 1- q-7 4-ILB-MRM
Dear Mr. Lappan:
In connection with the above-captioned case and pursuant to Fed. R. Crim. p.
16(a), as well as the Court's Criminal schedulingOrder,I am providing initial
discovery in the above matter on the enclosed DVD. I anticipate receivin g digital
forensic reports of cell phones, as well as a laptop andtabletin the coming days. The
reports will likely requile alarger storage medium for production. Once I receive the
reports, I will contact you to make the appropriate arrangements for further
discovery production.
In connection with the above captioned cases, please be advised of the
following:
1. With respect to the substance of any oral statement which the government
intends to offer in evidence attrialmadeby the defendantbefore or after arrest in
response to interrogation by any person then known to the defendant tobe a
governmerut agent, please be advised that the defendant did make such oral
statements to government agents, the substance of which is summarized in reports
that are being included in discovery.
Case 2:21-cr-00074-TPB-K_D     Document 37-1     Filed 09/28/21     Page 1 of 4 PageID 101

2. With respect to any relevant written or recorded statements made by the
defendant, please be advised that the United States is not in possession of recorded
statements made by the defendant.
3. The prior criminal record of the defendant will be made avatlable as part of
discovery.
4. As to Rule 16 documents and tangible objects, the government is providing
the documents which wil1be used in their case-in-chief in their electronic discovery
production. Please feel free to contact me or the case agent, USSS Special Agent
Philip DePietro, if you believe electronic production of such documents is
insufficient.
5. At this time, there are no reports of examinations and tests in connection
with this case.
6. At this time, the government does not intend to call an expert witness.
7. Electronic surveillance has not been conducted with respect to this
investigation.
8. At this time, the government does intend to introduce evidence pursuant to
Fed. R. Evid. 404@) in its case-in-chief in this matter. Specifically, the government
intends to introduce evidence pertaining to Amber Bruey's False Statement for
Public Aid case previously prosecuted in St. Lucie County under case
2018CF000164. The govemment believes the facts and circumstances of this prior
case would be admissible to prove motive, intent, knowledge, absence of mistake,
and lack of accident.
9. Confidential informants did not provide information during the course of
the investrgatton.
10. There is no known conflict of interest in the representation of the
defendant by attorneys in this case. Should such a conflict become known to the
government, counsel for the defendant will be alerted.
11. The defendant was not identified by means of photo identification.
Case 2:21-cr-00074-TPB-K_D     Document 37-1     Filed 09/28/21     Page 2 of 4 PageID 102

72. Evrdence was seized as a result of a search warrant. Copies of the
executed search warrant and affidavit are being included in discovery. Additionally,
evidence seized, which consists of digitally stored evidence on cell phones, alaptop,
andtablet, wil be made avatlable for copying and inspection.
13. We are aware of continuing discovery obligations pursuant to Fed. R.
Crim. P. 16(c) and will make you aware of such materials as soon as possible if such
materials come to our attention.
13. Pursuant to Fed. R. Crim. P. 16(b), the United States requests the
following:
a. 
Books, papers, documents, photographs, tangible objects, or
copies or portions thereof, which are within the possession, custody, or control of the
defendant and which the defendant intends to introduce as evidence in chief at the
trial. Fed. R. Crim. P. 16(bX1XA).
b. 
Any results or reports of physical or mental examinations and of
scientific tests or experiments made in connection with the particular case, or copies
thereof, within the possession or control of the defendant, which the defendant
intends to introduce as evidence in chief at the trial or which were preparedby a
witness whom the defendant intends to call atthe trial when the results or reports
relate to that witness'testimony. Fed. R. Crim. P. 16(bXlXB).
c. 
A written summary of testimony that the defendant intends to
use under Rule 702, 703, or 705 of the Federal Rules of Evidence as evidence attrtal,
describing the witnesses' opinions, the bases and reasons for those opinions and the
witnesses'qualifications. Fed. R. Crim. P. 16 (bXlXC).
Case 2:21-cr-00074-TPB-K_D     Document 37-1     Filed 09/28/21     Page 3 of 4 PageID 103

If you have any questions conceming any of the foregoing, please do not hesitate to
contact the undersigned.
Sincerely,
KARIN HOPPMANN
Acing United States Attorney
Assistant United States Attorney
Case 2:21-cr-00074-TPB-K_D     Document 37-1     Filed 09/28/21     Page 4 of 4 PageID 104

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