Anthony Bruey Discovery Letter — USA v. Bruey et al (Dkt. 37.2)

Record facts

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

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2110 First Street, Suite 3-137
Fort Myers, Florida 33901
239/46t-2200
239/46I-2219 (Fax)
35 SE lst Avenue, Suite 300
Ocala,Flondal44Tl
352/547-3600
352/s47-3623 (Fax)
U.S. Departrrent of Justice
United States Attomey
Middle District of Floicle
MainOffice
r()0 North Tampa Street, Suite 3200
Tampa, Florirla 33602
813/274-6000
813/274-6358 (Fax)
300 N. Hogan Street, Suite 700
Jacksonville, Fllorida 32202
904/301-6300
904/301-6310 (Fax)
4)0 West Washingtor SEeet, Suite 3100
Orlando, Florida 32801
N7 /648-7500
407/648-7643 (Fax)
Reply to: Fort Myers, FL
September 28,2021
Landon Miller
Mangone & Miller Law Offices
2335 Stanford Cr Ste 502
Naples, Florida 34112-4843
Re: United States v, Anthony James Braey
Case No. 2 :21- q-7 4-ILB-MRM
Dear Mr. Miller:
In connection with the above-captioned case and pursuant to Fed. R. Crim. P.
16(a), as wel1as 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 wellas a laptop andtablet in the coming days. The
reports will likely requke 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. V/ith respect to the substance of any oral statement which the government
intends to offer in evidence attrral made by the defendant before or after affest in
response to interrogation by any person then known to the defendant tobe a
government agent, please be advised that the defendant did make such oral
statements to government agents, the substance of which is summarized in reports
that arc being included in discovery.
Case 2:21-cr-00074-TPB-K_D     Document 37-2     Filed 09/28/21     Page 1 of 3 PageID 105

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 will be 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 not intend to introduce evidence
pursuant to Fed. R. Evid. 404b) in its case-in-chief in this matter for defendant
Anthony James Bruey.
9. Confidential informants did not provide information during the course of
the investigation.
10. There is no known conflict of interest in the representation of the
defendant by afforneys 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.
12. Evrdence was seized as a result of a search warrant. Copies of the
executed search warrant and affidavit are being included in discovery. Additionally,
Case 2:21-cr-00074-TPB-K_D     Document 37-2     Filed 09/28/21     Page 2 of 3 PageID 106

evidence seized, which consists of digitally stored evidence on cell phones, alaptop,
andtablet, wil be made avarTable for copyingand 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 affention.
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 conffol 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(b)(lXB).
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 atfftal,
describing the witnesses' opinions, the bases and reasons for those opinions and the
witnesses'qualifications. Fed. R. Crim. P.16 @X1XC).
If you have any questions concerning any of the foregoing, please do not
hesitate to contact the undersigned.
Sincerely,
KARIN HOPPMANN
Acing United States Afforney
Trenton J. Reichling
Assistant United States Attorney
By:
Case 2:21-cr-00074-TPB-K_D     Document 37-2     Filed 09/28/21     Page 3 of 3 PageID 107

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