Government's Second Response to the Standing Discovery Order

Record facts

U.S. District Court for the Southern District of Florida · No. 1:21-cr-20231-DMM · Doc. 24 · 2021-05-18 · Docket on CourtListener

Summary

The government's second response to the Standing Discovery Order, entered May 18, 2021 as Doc. 24 in United States v. Carlos Vazquez, No. 1:21-cr-20231-DMM, in the U.S. District Court for the Southern District of Florida. The response states that its attachments are Bates numbers USA_1328 through USA_1338 and were served by email. It offers defense counsel the chance to inspect tangible evidence at the U.S. Attorney's Office with reasonable notice and acknowledges the government's continuing disclosure duties under Rule 16(c), Brady, Giglio and Napue. The government also reiterates its demand for reciprocal discovery under Rules 16(b) and 26.2 of the Federal Rules of Criminal Procedure. The three-page filing is signed by Assistant United States Attorney Hayden P. O'Byrne and includes a certificate of service and service list naming defense counsel Carlos M. Fleites.

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Full text

1 
 
UNITED STATES DISTRICT COURT  
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO. 21-CR-20231-DMM 
 
UNITED STATES OF AMERICA 
 
vs. 
 
CARLOS VAZQUEZ, 
 
Defendant. 
  
/ 
 
GOVERNMENT=S SECOND RESPONSE TO  
THE STANDING DISCOVERY ORDER 
 
The United States hereby files this second response to the Standing Discovery Order.  The 
attachments to this response are comprised of bates numbers USA_1328 through USA_1338.  The materials 
were served via email this afternoon.  Please contact the undersigned Assistant United States Attorney if 
any portion of this discovery production appears to be missing. Counsel for the defendant may inspect any 
item of tangible evidence reflected in the discovery, any item of evidence that was seized from your client, 
and any item that the United States intends to offer in its case-in-chief, with reasonable notice, at the Office 
of the United States Attorney, located at 99 Northeast 4th Street, Miami, Florida.  
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. 
 
 
 
 
 
 
Case 1:21-cr-20231-DMM   Document 24   Entered on FLSD Docket 05/18/2021   Page 1 of 3

2 
 
In addition to the request made above by the government pursuant to the Standing Discovery Order 
and Rule 16(b) of the Federal Rules of Criminal Procedure, in accordance with Rule 12.1 of the Federal 
Rules of Criminal Procedure, the government hereby reiterates its demand for all reciprocal discovery it is 
entitled to under Rules 16(b) and 26.2 of the Federal Rules of Criminal Procedure.   
 
Respectfully submitted, 
 
JUAN ANTONIO GONZALEZ 
ACTING UNITED STATES ATTORNEY 
 
By:  /s/ Hayden P. O’Byrne 
Hayden P. O’Byrne 
Assistant United States 
Attorney Florida Bar No. 60024 
United States Attorney’s Office - SDFL 99 
Northeast 4th Street 
Miami, FL. 33132-2111 
Tel: (305) 961-9447 
Hayden.obyrne@usdoj.gov 
Case 1:21-cr-20231-DMM   Document 24   Entered on FLSD Docket 05/18/2021   Page 2 of 3

5 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on May 10, 2021, I electronically filed the foregoing document 
with the Clerk of the Court using CM/ECF. I also certify that I caused the foregoing document to 
be served this day on all counsel of record on the Service List below in the manner specified. 
 
 
/s/ Hayden P. O’Byrne 
 
Hayden P. O’Byrne 
Assistant United States Attorney 
 
 
SERVICE LIST 
 
Party 
Counsel 
Manner of Service 
 
 
Carlos Vazquez 
Carlos M. Fleites 
Law Offices of Carlos M Fleites 
1800 SW 27th Ave, Suite 500 
Miami, Florida 33145 
CM/ECF without 
attachments. 
U.S. Mail with 
attachments. 
 
Case 1:21-cr-20231-DMM   Document 24   Entered on FLSD Docket 05/18/2021   Page 3 of 3

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