Discovery Letter — USA v. Crowther (Dkt. 24-1, M.D. Fla. No. 2:20-mj-01094, docketed in No. 2:20-cr-00114)

Record facts

U.S. District Court for the Middle District of Florida · No. 2:20-cr-00114 · Doc. 24-1 · 2020-10-07 · Docket on CourtListener

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2110  First Street, Suite 3-137 
Fort Myers, Florida 33901 
239/461-2200 
239/461-2219 (Fax) 
 
300 N. Hogan Street, Suite 700 
Jacksonville, Florida 32202 
904/301-6300 
904/301-6310 (Fax) 
 
U.S. Department of Justice 
 
35 SE 1st Avenue, Suite 300 
Ocala, Florida 34471 
352/547-3600 
352/547-3623 (Fax) 
United States Attorney 
Middle District of Florida 
 
Main Office 
400 North Tampa Street, Suite 3200 
Tampa, Florida 33602 
813/274-6000 
813/274-6358 (Fax) 
 
400 West Washington Street, Suite 3100 
Orlando, Florida 32801 
407/648-7500 
407/648-7643 (Fax) 
Reply to: Fort Myers, FL 
 
 
 
October 7, 2020 
 
Nicole Hughes Waid  
Fisher Broyles, LLP 
2390 Tamiami Trail North, Suite 100 
Naples, FL 34103 
 
 
Re: United States v. Casey David Crowther    
 
Case No. 2:20-cr-114-FtM-66MRM 
 
Dear Ms. Waid: 
 
 
In connection with the above-captioned cases and pursuant to Fed. R. Crim. 
P. 16(a) as well as the Court’s Criminal Scheduling Orders, the government has 
uploaded discovery onto USAFX.  
 
In connection with the above captioned cases, please be advised of the 
following: 
 
 
1.  With respect to the substance of any oral statement which the government 
intends to offer in evidence at trial made by the defendant before or after arrest in 
response to interrogation by any person then known to the defendant to be a 
government agent, please be advised that the defendant did not make such oral 
statements to government agents. 
 
 
2.  With respect to any relevant written or recorded statements made by the 
defendant, please be advised that the United States is not in possession of recorded 
statements made by the defendant. 
Case 2:20-cr-00114-JES-M_M     Document 24-1     Filed 10/07/20     Page 1 of 3 PageID 60

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3.  The prior criminal record of the defendant has been made available as part 
of discovery. 
 
 
4.  As to Rule 16 documents and tangible objects, the government is providing 
the documents which will be used in their case-in-chief in their electronic discovery 
production. Please feel free to contact me or the case agent, USSS Senior Special 
Agent Brian Kirby, if you believe electronic production of such documents is 
insufficient.  
 
 
5.  There are not reports of examinations and tests in connection with this 
case at this time. 
 
 
6.  At this time, the government does not intend to call an expert witness.  
 
 
7.  Electronic surveillance has not been conducted with respect to this 
investigation. 
 
 
8.  At this time, the government does not intend to introduce evidence 
pursuant to Fed. R. Evid. 404(b) in its case-in-chief in this matter.  
 
 
9.  Confidential informants did not provide information during the course of 
the investigation. 
 
10.  There is no known conflict of interest in the representation of the 
defendant by attorneys in this case.  Should such a conflict become known to the 
government, counsel for the defendant will be alerted 
 
 
11.  The defendant was not identified by means of photo identification.   
 
 
12.  Evidence was not seized as a result of search warrants.   
 
 
 
 
13.  We are aware of continuing discovery obligations pursuant to Fed. R. 
Crim. P. 16(c) and will make you aware of such materials as soon as possible if such 
materials come to our attention.   
 
 
Case 2:20-cr-00114-JES-M_M     Document 24-1     Filed 10/07/20     Page 2 of 3 PageID 61

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13.  Pursuant to Fed. R. Crim. P. 16(b), the United States requests the 
following: 
 
 
 
a. 
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 chief at the 
trial.  Fed. R. Crim. P. 16(b)(1)(A).   
 
 
 
b. 
Any results or reports of physical or mental examinations and of 
scientific tests or experiments made in connection with the particular case, or copies 
thereof, within the possession or control of the defendant, which the defendant 
intends to introduce as evidence in chief at the trial or which were prepared by a 
witness whom the defendant intends to call at the trial when the results or reports 
relate to that witness' testimony.  Fed. R. Crim. P. 16(b)(1)(B). 
 
 
 
c. 
A written summary of testimony that the defendant intends to 
use under Rule 702, 703, or 705 of the Federal Rules of Evidence as evidence at trial, 
describing the witnesses' opinions, the bases and reasons for those opinions and the 
witnesses' qualifications.  Fed. R. Crim. P. 16 (b)(1)(C). 
 
 
If you have any questions concerning any of the foregoing, please do not 
hesitate to contact the undersigned.   
 
 
Sincerely, 
 
 
MARIA CHAPA LOPEZ 
 
United States Attorney 
 
 
By:     ___________________________  
 
Trenton J. Reichling  
 
Assistant United States Attorney 
Case 2:20-cr-00114-JES-M_M     Document 24-1     Filed 10/07/20     Page 3 of 3 PageID 62

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