First Supplemental Response of the United States to Defendant's Standard Discovery Requests, and Request of the United States for Reciprocal Discovery — United States v. Omar (S.D. W. Va.)

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The government's first supplemental response to the defendant's standard discovery requests in United States v. Anna Marie Omar, Criminal No. 1:24-CR-00036, U.S. District Court for the Southern District of West Virginia at Bluefield, filed 07/17/24 as Document 24 (3 pages). Under Rule 16, it lists three one-page Small Business Administration records provided to the defense: a Certificate of Indebtedness, a Certified Statement of Account and a Transcript of Account, each as to the defendant. It also asks the defendant to provide reciprocal discovery within 14 days. The filing does not state the charges or any amounts.

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UNITED STATES DISTRICT COURT 
 
SOUTHERN DISTRICT OF WEST VIRGINIA 
BLUEFIELD 
 
 
UNITED STATES OF AMERICA 
 
 
v. 
 
 
 
 
 
 
CRIMINAL NO. 1:24-CR-00036 
 
 
ANNA MARIE OMAR 
 
 
FIRST SUPPLEMENTAL RESPONSE OF THE UNITED STATES 
 TO DEFENDANT’S STANDARD DISCOVERY REQUESTS, AND  
REQUEST OF THE UNITED STATES FOR RECIPROCAL DISCOVERY 
 
 
Pursuant to Rule 16 of the Federal Rules of Criminal 
Procedure, Rule 16.1(a) of the Local Rules of Criminal Procedure, 
and the Arraignment Order and Standard Discovery Request entered 
by the Court in this case, the United States of America, by 
counsel, herewith supplements its previous response to the 
defendant's Standard Discovery Requests as follows: 
 
 
Request E:  Permit the defendant to inspect and to copy 
or photograph books, papers, documents, data, photographs, 
tangible objects, building or places, or copies or portions of any 
of those items, if the item is within the government’s possession, 
custody or control, and (i) the item is material to preparing the 
defense; (ii) the government intends to use the item in its case-
in-chief at trial; or (iii) the item was obtained from or belongs 
to defendant.  [Fed. R. Crim. P. 16(a)(1)(E)] 
 
 
Response:  The following has been provided: 
 
1. 
Small 
Business 
Administration 
“Certificate 
of 
Indebtedness” as to the defendant (1 page); 
Case 1:24-cr-00036     Document 24     Filed 07/17/24     Page 1 of 3 PageID #: 65

2 
 
2. 
Small Business Administration “Certified Statement of 
Account” as to the defendant (1 page); and  
3. 
Small Business Administration “Transcript of Account” as 
to the defendant (1 page). 
 
REQUEST OF THE UNITED STATES FOR RECIPROCAL DISCOVERY 
 
Pursuant to Rules 16.1(b) and 16.1(d) of the Local Rules of 
Criminal Procedure, the United States of America requests that 
defendant provide all applicable reciprocal discovery within 14 
days of the service of this response and the provision of materials 
requested by defendant in the Standard Discovery Request. 
Respectfully submitted, 
 
WILLIAM S. THOMPSON 
United States Attorney 
 
 
 
 
 
By: 
/s/ Jonathan T. Storage 
JONATHAN T. STORAGE 
Assistant United States Attorney 
WV Bar No. 12279 
 
 
 
 
 
 
300 Virginia Street, East 
 
 
 
 
 
 
Room 4000 
 
 
 
 
 
 
Charleston, WV 25301 
 
 
 
 
 
 
Telephone:  304-345-2200  
 
 
 
 
 
 
 
Email:  Jonathan.Storage@usdoj.gov 
 
 
Case 1:24-cr-00036     Document 24     Filed 07/17/24     Page 2 of 3 PageID #: 66

3 
 
CERTIFICATE OF SERVICE 
It is hereby certified that the foregoing “FIRST SUPPLEMENTAL 
RESPONSE OF THE UNITED STATES TO DEFENDANT’S STANDARD DISCOVERY 
REQUESTS, AND REQUEST OF THE UNITED STATES FOR RECIPROCAL 
DISCOVERY” has been electronically filed and service has been made 
on opposing counsel by virtue of such electronic filing this 17th 
day of July, 2024, to: 
 
Clint Carte, Esq. 
Office of the Federal Public Defender 
300 Virginia Street, East, Suite 3400 
Charleston, West Virginia 25301 
 
 
 
 
/s/Jonathan T. Storage 
JONATHAN T. STORAGE 
Assistant United States Attorney 
WV Bar No.12278  
300 Virginia Street, East 
Room 4000 
Charleston, WV 25301 
Telephone:  304-345-2200 
Fax: 304-347-5104 
Email: Jonathan.Storage@usdoj.gov 
 
Case 1:24-cr-00036     Document 24     Filed 07/17/24     Page 3 of 3 PageID #: 67

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