Government's Third 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. 35 · 2021-07-29 · Docket on CourtListener

Summary

The government's third response to the Standing Discovery Order in United States v. Carlos Vazquez, No. 1:21-cr-20231-DMM, in the U.S. District Court for the Southern District of Florida, entered July 29, 2021 as Doc. 35. The response states that its attachments are bates numbers USA_1339 through USA_1352 and were served by email. It notes that electronic devices seized during the execution of a search warrant on March 23, 2021 have been examined and are available for defense review. The government acknowledges its continuing disclosure duties under Rule 16(c), Brady, Giglio and Napue, and reiterates its demand for reciprocal discovery under Rules 16(b) and 26.2. It is signed by Assistant United States Attorney Hayden P. O'Byrne and includes a certificate of service on defense counsel Albert Z. Levine.

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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 THIRD RESPONSE TO  
THE STANDING DISCOVERY ORDER 
 
The United States hereby files this third response to the Standing Discovery Order.  The 
attachments to this response are comprised of bates numbers USA_1339 through USA_1352.  The materials 
were served via email today.  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.  PLEASE NOTE: Electronic Devices seized during the execution of the search 
warrant on March 23, 2021 have been examined and is available for your review.  Please contact the 
undersigned Assistant United States Attorney if you wish to make arrangements to review same.  
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. 
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 
Case 1:21-cr-20231-DMM   Document 35   Entered on FLSD Docket 07/29/2021   Page 1 of 3

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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 35   Entered on FLSD Docket 07/29/2021   Page 2 of 3

5 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on July29, 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 
Albert Z. Levine 
Albert Z. Levine, P.A.  
40 N.W. 3rd Street 
Suite 200 
Miami, FL 33128 
albert@albertlevinelaw.com 
 
CM/ECF without 
attachments. 
Email with 
attachments. 
 
Case 1:21-cr-20231-DMM   Document 35   Entered on FLSD Docket 07/29/2021   Page 3 of 3

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