Motion for Reciprocal Discovery by Jennifer Ashley Stanley — USA v. Thurmond et. al. (Dkt. 31, S.D. Ga.)

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In this Government's Motion for Reciprocal Discovery, Document 31 filed 04/21/23 in United States of America v. Brandon Jamal Thurmond and La'Kyera Me'Lika Thurmond, Case No. 1:23-CR-021 in the Southern District of Georgia, the United States cites the liberal discovery it has already provided. It asks the Court to order the Defendant to provide reciprocal discovery no later than two weeks prior to trial. The listed categories are documents and objects the Defendant intends to introduce in his case-in-chief, reports of examinations and tests, written summaries of expert witness testimony, and prior statements of defense witnesses. The motion also asks that, within 14 days of the request, the Defendant give written notice of any intended alibi defense and seeks to exclude insanity or mental condition evidence unless written notice is provided.

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF GEORGIA 
AUGUSTA DIVISION 
 
UNITED STATES OF AMERICA 
 
) 
CASE NO: 1:23-CR-021 
 
 
 
 
 
 
 
) 
v. 
 
 
 
 
 
 
) 
 
 
 
 
 
 
 
) 
BRANDON JAMAL THURMOND   
) 
and   
 
 
 
 
 
) 
LA’KYERA ME’LIKA THURMOND  
) 
  
GOVERNMENT’S MOTION FOR RECIPROCAL DISCOVERY 
Now comes the United States of America, by and through Jill E. Steinberg, 
United States Attorney for the Southern District of Georgia, and the undersigned 
Assistant United States Attorney, and moves as follows: 
In light of the liberal discovery previously provided by the Government to the 
Defendant in this case, the Government moves the Court to order the Defendant in 
the above captioned case to provide the Government with reciprocal discovery by no 
later than two weeks prior to trial, to include: 
1. 
Documents and Objects: 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 his case-in-chief at the trial.  See Fed. R. Crim. P. 16(b)(1)(A). 
2. 
Reports of Examinations and Tests:  Results or reports of physical 
or mental examinations and of scientific tests or experiments made in connection with 
this particular case, or copies thereof, within the possession or control of the 
Defendant which the Defendant intends to introduce as evidence in his case-in-chief 
Case 1:23-cr-00021-JRH-BKE     Document 31     Filed 04/21/23     Page 1 of 4

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at the trial or which were prepared by witnesses whom the Defendant intends to call 
at the trial when the results or reports relate to their testimony.  See Fed. R. Crim. 
P. 16(b)(1)(B). 
3. 
Expert Witnesses: A written summary of any testimony that the 
Defendant intends to use under Rules 702, 703, or 705 of the Federal Rules of 
Evidence as evidence at trial, describing the expert witness=s opinions, the bases and 
reasons for those opinions, and the witness=s qualifications.  See Fed. R. Crim. P. 
16(b)(1)(c). 
4. 
Prior Statements of Defense Witnesses:  All prior statements in the 
possession of the Defendant, if any, given by witnesses whom the Defendant expects 
to call at trial other than the Defendant himself.  The term “statements” is to be 
construed by the Defendant as it is defined in Fed. R. Crim. P. 26.2 (effective 
December 1, 1980) and the Jencks Act, codified at 18 U.S.C. § 3500.  See Fed. R. Crim. 
P. 26.2 and United States v. Nobles, 422 U.S. 225 (1975). 
Pursuant to Rule 12.1, the United States requests that, within 14 days of this 
request, Defendant provide written notice of any intended alibi defense that states 
each specific place where Defendant claims to have been at the time of the alleged 
offense, and the name, address, and telephone number of each alibi witness on whom 
Defendant intends to rely. 
Pursuant to Rule 12.2, the United States seeks to exclude any evidence relating 
to a defense of insanity, or a mental disease or defect or any other mental condition 
Case 1:23-cr-00021-JRH-BKE     Document 31     Filed 04/21/23     Page 2 of 4

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of Defendant bearing on the issue of guilt, unless and until Defendant provide the 
requisite written notice of such defense and evidence as required by Rule 12.2(a)–(b). 
See Fed. R. Crim. P. 12.2(d)(1)(A). 
Pursuant to Rule 12.3, the United States requests written notice of any actual 
or believed exercise of public authority on behalf of a law enforcement agency or 
federal intelligence agency at the time of the offense. 
Pursuant to Rules 12.1(c) and 16(c), the United States requests that Defendant 
promptly disclose any discoverable material in which it becomes aware as part of its 
continuing disclosure duty. 
Respectfully submitted this 21st day of April, 2023. 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
JILL E. STEINBERG 
 
 
 
 
 
 
UNITED STATES ATTORNEY 
 
 
 
 
 
s/ Jennifer Stanley 
 
 
 
 
 
 
Jennifer Stanley 
 
 
 
 
 
 
Assistant United States Attorney 
 
 
 
 
 
 
Alabama Bar No. 8400E77T  
United States Attorney’s Office 
Southern District of Georgia 
P.O. Box 2017 
 
Augusta, Georgia 30903 
T: (706) 826-4525 
jennifer.stanley@usdoj.gov 
 
 
Case 1:23-cr-00021-JRH-BKE     Document 31     Filed 04/21/23     Page 3 of 4

4 
 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF GEORGIA 
AUGUSTA DIVISION 
 
UNITED STATES OF AMERICA 
 
) 
CASE NO: 1:23-CR-021 
 
 
 
 
 
 
 
) 
v. 
 
 
 
 
 
 
) 
 
 
 
 
 
 
 
) 
BRANDON JAMAL THURMOND   
) 
and  
 
 
 
 
 
) 
LA’KYERA ME’LIKA THURMOND  
) 
 
CERTIFICATE OF SERVICE 
 
This is to certify that I have on this day served all the parties in this case in 
accordance with the notice of electronic filing (“NEF”) which was generated as a 
result of electronic filing in this Court. 
This 21st day of April, 2023. 
 
 
 
 
 
Respectfully submitted, 
 
 
 
 
 
 
 
JILL E. STEINBERG 
 
 
 
 
 
 
UNITED STATES ATTORNEY 
 
 
 
s/ Jennifer Stanley 
 
 
 
 
 
 
Jennifer Stanley 
 
 
 
 
 
 
Assistant United States Attorney 
 
 
 
 
 
 
Alabama Bar No. 8400E77T  
United States Attorney’s Office 
Southern District of Georgia 
P.O. Box 2017 
 
Augusta, Georgia 30903 
T: (706) 826-4525 
jennifer.stanley@usdoj.gov 
 
Case 1:23-cr-00021-JRH-BKE     Document 31     Filed 04/21/23     Page 4 of 4

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