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Home Court filings USA v. Vazquez — U.S. District Court, Southern District of Florida Government's Seventh Response to the Standing Discovery Order

Court filing

Government's Seventh Response to the Standing Discovery Order

Record facts

CourtU.S. District Court for the Southern District of Florida
Filed2021-11-02

U.S. District Court for the Southern District of Florida · No. 1:21-cr-20231-DMM · Doc. 53 · 2021-11-02 · Docket on CourtListener

Summary

The government's seventh response to the Standing Discovery Order in United States of America v. Carlos Vazquez, Case No. 21-CR-20231-DMM, in the U.S. District Court for the Southern District of Florida, filed November 2, 2021 as Doc. 53. The response states that its attachment, bates number USA_1359-1392, consists of immigration documents pertaining to the defendant, an email from the defendant's prior counsel, memoranda of interviews and a quitclaim deed. It states that United States Immigration and Customs Enforcement holds the defendant's complete alien file and may offer additional materials at sentencing. The government acknowledges its continuing disclosure duty 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.

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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 SEVENTH RESPONSE TO  
THE STANDING DISCOVERY ORDER 
 
The United States hereby files this Seventh response to the Standing Discovery Order.  The 
attachment to this response is comprised of bates number USA_1359-1392 and consist of immigration 
documents pertaining to the defendant, an email from Defendant’s prior counsel, memoranda of interviews 
and quitclaim deed.  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 at 
sentencing with reasonable notice, at the Office of the United States Attorney, located at 99 Northeast 4th 
Street, Miami, Florida.  Notably, United States Immigration and Customs Enforcement has Defendant’s 
complete alien file and may offer additional materials from this file at Defendant’s sentencing.  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 
Case 1:21-cr-20231-DMM   Document 53   Entered on FLSD Docket 11/02/2021   Page 1 of 3

2 
 
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 
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 53   Entered on FLSD Docket 11/02/2021   Page 2 of 3

5 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on November 2, 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 53   Entered on FLSD Docket 11/02/2021   Page 3 of 3

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