Scheduling Order as to Christopher Leo — USA v. Daragjati (Dkt. 19, M.D. Fla.)

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U.S. District Court for the Middle District of Florida · No. 3:23-cr-00048-TJC-LLL · Doc. 19 · 2023-04-03 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
MIDDLE DISTRICT OF FLORIDA 
JACKSONVILLE DIVISION 
 
UNITED STATES OF AMERICA 
 
 
vs. 
NO. 3:23-CR-48-TJC-LLL 
CHRISTOPHER LEO DARAGJATI 
 
 
 
JUDGE CORRIGAN'S STANDING ORDER PERTAINING TO 
DISCOVERY, MOTIONS, HEARINGS, CONFERENCES AND TRIAL 
 
I.  HEARINGS, CONFERENCES AND TRIAL 
 
A. 
DISCOVERY MOTIONS TO BE FILED BY: 
    
APRIL 17, 2023 
 
 
 
(Any necessary hearing will be set by separate notice)* 
 
B. 
DISPOSITIVE MOTIONS, MOTIONS TO SUPPRESS AND OTHER 
NON-DISCOVERY MOTIONS ARE TO BE FILED BY: 
APRIL 17, 2023 
 
 
 
(Any necessary hearings will be set by separate notice) 
 
C. 
STATUS CONFERENCE*: 
 
 
Date: MAY 22, 2023 
Time: 4:00 P.M._ 
 
 
Courtroom Number: 
    10D (10th Floor)      
 
ALL CHANGE OF PLEA HEARINGS SHALL BE SCHEDULED AS 
SOON AS POSSIBLE BEFORE THE ASSIGNED MAGISTRATE 
JUDGE 
 
D. 
Trial Term Commencing On: 
 
 
Date: JUNE 5, 2023_ 
Time: 9:00 A.M._ 
 
 
Courtroom Number:    10D (10th Floor)____ 
 
 
300 North Hogan Street, Jacksonville, Florida 
 
 
 
*Defendants are not required to be present at Discovery Hearings or 
Status Conferences. 
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II.  RULES - DISCOVERY UNDER STANDING ORDER 
 
Defendant(s) may accept the following discovery by filing with the Court a 
Notice of Acceptance of General Discovery within ten (10) working days hereof, or as 
otherwise directed by the Court.  Within the time frame established in Part I of this 
Order, any party may file additional motions concerning discovery matters not covered 
by this Order or to seek a revision of the discovery deadlines established in this Order. 
A. 
Within ten (10) working days from the filing of the Notice of Acceptance 
of General Discovery, the Government shall disclose to the defendant(s) 
and make available for inspection, copying, or photographing: 
1. 
any relevant written or recorded statement made by the 
defendant(s), or copies thereof, within the possession, custody or 
control of the Government, the existence of which is known, or by 
the exercise of due diligence may become known, to the attorney 
for the Government; and 
2. 
that portion of any written record containing the substance of any 
relevant oral statement made by the defendant whether before or 
after arrest in response to interrogation by any person then known 
to the defendant to be a government agent; 
3. 
the substance of any other relevant oral statement, if the 
Government intends to use that statement at trial (including for 
impeachment), made by the defendant(s) whether before or after 
arrest in response to interrogation by any person then known to the 
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(Revised 4-13-10 - Judge Corrigan) Page 3 
 
defendant(s) to be a Government agent; and 
4. 
recorded testimony of the defendant(s) before a grand jury which 
relates to the offense charged; and 
5. 
books, papers, documents, photographs, tangible objects, buildings, 
or places or copies or portions thereof, which are within the 
possession, custody or control of the Government, which: 
a. 
are material to the preparation of the defense; or 
b. 
are intended for use by the Government as evidence in its 
case in chief; or 
c. 
were obtained from or belong to the defendant; and 
6. 
results or reports of physical or mental examinations, and scientific 
tests or experiments, or copies thereof, which are within the 
possession, custody or control of the Government, the existence of 
which is known, or by the exercise of due diligence may become 
known, to the attorney for the Government, which: 
a. 
are material to the preparation of the defense; or 
b. 
are intended for use by the Government as evidence in its 
case in chief. 
B. 
No later than twenty (20) working days before trial (unless this deadline is 
modified upon good cause shown) the government should comply with 
Rule 16(a)(1)(G), Fed.R.Crim.P., regarding disclosure of a written 
summary of the testimony of expert witnesses.  No later than five (5) 
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(Revised 4-13-10 - Judge Corrigan) Page 4 
 
working days before trial (unless this deadline is modified upon good cause 
shown) the defendant(s) should comply with the reciprocal disclosure 
provisions 
concerning 
experts 
contained 
in 
Rule 
16(b)(1)(C), 
Fed.R.Crim.P. 
C. 
Within ten (10) working days from the filing of the Notice of Acceptance 
of General Discovery, the Government shall furnish the defendant(s) such 
copy of his prior criminal records, if any, as is within the possession, 
custody, or control of the Government, the existence of which is known, 
or by the exercise of due diligence may become known, to the attorney for 
the Government. 
D. 
The Government shall provide reasonable notice in advance of and at least 
ten (10) working days before trial the general nature of any evidence of 
other crimes, wrongs or acts which it intends to introduce at trial, either in 
its case in chief, for impeachment, or possible rebuttal, pursuant to Rule 
404 (b), Fed.R.Evid.  Such notice may be made during trial if the Court 
excuses pretrial notice on good cause shown. 
E. 
Not later than five (5) working days before trial, the Government shall 
reveal to the defendant(s) all information and material known to the 
Government which may be favorable to the defendant(s) on the issue of 
guilt or punishment within the scope of Brady v. Maryland, 373 U.S. 83 
(1963). 
F. 
Where so stated, the Government shall exercise due diligence to make 
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(Revised 4-13-10 - Judge Corrigan) Page 5 
 
known the matters covered by this Order. 
G. 
Upon compliance by the Government with Paragraphs A.5 and A.6 of this 
Order, the defendant(s), within five (5) working days after said 
compliance, shall permit the Government to inspect and copy or 
photograph:  
1. 
Books, papers, documents, photographs, tangible objects, or copies 
or portions thereof, which are within the possession, custody, or 
control of the defendant(s), and which the defendant(s) intends to  
introduce in his case in chief at trial; and  
2. 
Results or reports of physical or mental examinations and of 
scientific tests or experiments made in connection with this case, or 
copies thereof, within the possession or control of the defendant(s), 
which:  
a. 
the defendant(s) intends to introduce as evidence in his case 
in chief at trial; or  
b. 
were prepared by a witness whom the defendant(s) intends to 
call at the trial when the results or reports relate to that  
witness' testimony. 
H. 
If, prior to or during trial, a party discovers additional evidence or material 
previously required to be disclosed by Order of this Court, he shall 
promptly notify the attorney for the other party, or the defendant(s), if he 
or she is not represented by counsel, of the existence of the additional 
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evidence or material. 
I. 
In accordance with Rule 12.2, Fed.R.Crim.P., if the defendant(s) intends 
to rely upon the defense of insanity at the time of the alleged crime, or if 
he intends to introduce expert testimony relating to a mental disease, 
defect, or other condition bearing upon the issue of his mental state, he 
should comply with the notification procedure as set forth in said Rule 
within ten (10) working days of the date hereof. 
J. 
In accordance with Rule 12.1, Fed.R.Crim.P., if the Government makes a 
written demand concerning an alibi, the defendant shall comply with the 
notification procedure set forth in said Rule within fourteen (14) working 
days from the service of said written demand.  Upon receipt of the notice 
of alibi by the Government, the provisions of Rule 12.1(b), Fed.R.Crim.P., 
shall be complied with. 
K. 
The Court strongly encourages the Government to agree to produce 
Jencks Act materials before required to do so to give defendant(s) sufficient 
time to effectively utilize them in preparation for trial.  In the typical case 
(where there are no witness safety or other concerns), disclosure should be 
made at least five (5) working days before trial (earlier disclosure may be 
appropriate in a given case).  The parties are also strongly encouraged, 
but not required, to agree to a reciprocal witness list exchange five (5) 
working days before trial.  (In any event, witness lists must be provided 
by all parties at the commencement of trial.) 
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III.  RULES - DISCOVERY BY WRITTEN MOTIONS 
 
If the defendant(s) elect not to accept Rules - Discovery Under Standing Order 
as stated in Part II, the defendant(s) shall file motions for Discovery within the time 
provided in Part I of this Order. 
DONE AND ORDERED at Jacksonville, Florida on April 3, 2023.  
 
 
 
 
 
By: /s/ Natasa Kojic 
  
 
Deputy Clerk 
 
 
 
 
Copies to: 
Kevin C. Frein, Assistant United States Attorney 
Scott T. Schmidt, Esquire 
United States Marshal 
United States Probation Office 
United States Pretrial Services Office 
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