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Home Court filings USA v. Watson United States v. Edrica Leann Watson — M.D. Fla., Fort Myers Division Exhibit — USA v. Watson (Dkt. 21.1)

Court filing

Exhibit — USA v. Watson (Dkt. 21.1)

Filed December 20, 2021 in USA v. Watson; one of 20 filings from this case.

Record facts

CourtU.S. District Court for the Middle District of Florida
Filed2021-12-20

U.S. District Court for the Middle District of Florida · No. 2:21-cr-00107-SPC-KRH · Doc. 21-1 · 2021-12-20 · Docket on CourtListener

Full text

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 
SL/cc 
 
 
December 20, 2021 
 
 
James Lappan 
Federal Public Defender’s Office  
2075 West First Street, Suite 300 
Fort Myers, FL 33901 
 
Re: United States v. Edrica Leann Watson 
Case No. 2:21-cr-107-SPC-MRM 
 
Dear Mr. Lappan: 
 
In connection with the above-captioned case, and pursuant to Fed. R. Crim. P. 
16(a) as well as the Court’s Criminal Scheduling Order, the United States is providing 
you with discovery materials via USAfx.  You will be required to sign a receipt for the 
materials provided, which has also been provided via USAfx.    
 
In connection with the above captioned case, please also be advised of the 
following: 
 
 Rule 16(a)(1)(A): Defendant's Oral Statement.  There have been oral statements 
made by the defendant in response to interrogation that the Government intends 
to use in trial at this time.   
 
 Rule 16(a)(1)(B): Defendant's Written or Recorded Statement. Any written or 
recorded statement made by the defendant has been included as part of 
discovery in this case. See, e.g., Interview provided as part of discovery disclosure. 
 
Case 2:21-cr-00107-SPC-KRH     Document 21-1     Filed 12/20/21     Page 1 of 4 PageID 54

James Lappan 
December 20, 2021 
Page 2 
 
 Rule 16(a)(1)(C): Organizational Defendant. The defendant is not an 
“organization defendant.” 
 
 Rule 16(a)(1)(D): Defendant’s Prior Record.  The defendant does not have any 
prior criminal convictions.  
 
 Rule 16(a)(1)(E): Documents and Objects. As to Rule 16 documents and tangible 
objects, you are free to inspect such items which will be used by the government 
in its case-in-chief by contacting the case agent, USSS Corey Graves and 
scheduling an appointment for viewing and inspection at a mutually convenient 
time. 
 
 Rule 16(a)(1)(F): At this time, there are no Report of Examinations and Tests.  
 
 Rule 16(a)(1)(G): Expert Witnesses. At this time, the government does not intend 
to call an expert witness. 
 
 Additional Disclosures and Discovery ¶ (1)(a—b): At this time, there is no 
electronic surveillance conducted by witnesses or law enforcement or mail 
covers that law enforcement officers and witnesses used in investigating this 
case, at this time, there are no transcripts from the electronic surveillance.  
 
 Additional Disclosures and Discovery ¶ (1)(c):  Evidence has been collected 
through search warrants that the United States intends to introduce during trial 
in this case.    
 
 Additional Disclosures and Discovery ¶ (1)(d): No confidential informants were 
used during this investigation. 
 
 Additional Disclosures and Discovery ¶ (1)(e—f): At this time, no witness has 
identified the defendant in a photo lineup which was been provided as part of 
discovery.    
 
 Additional Disclosures and Discovery ¶ (1)(g): At this time, there are no latent 
fingerprints that a government expert has identified as belonging to Defendant 
for independent examination.    
Case 2:21-cr-00107-SPC-KRH     Document 21-1     Filed 12/20/21     Page 2 of 4 PageID 55

James Lappan 
December 20, 2021 
Page 3 
 
 
 Additional Disclosures and Discovery ¶ (1)(h): At this time, the United States 
does not intend to introduce prior act evidence pursuant to Fed. R. Evid. 404(b) 
in this case. 
 
 Additional Disclosures and Discovery ¶ (1)(i):  There are no known conflicts of 
interest in this case at this time. 
 
 
 
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.   
 
 
 
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). 
 
 
 
 
 
 
Case 2:21-cr-00107-SPC-KRH     Document 21-1     Filed 12/20/21     Page 3 of 4 PageID 56

James Lappan 
December 20, 2021 
Page 4 
 
 
If you have any questions concerning any of the foregoing, please do not 
hesitate to contact the undersigned.   
 
 
 
 
 
 
 
Sincerely, 
 
 
 
By: 
/s Shannon Laurie_____     
 
Shannon Laurie  
 
Assistant United States Attorney 
 
 
 
Case 2:21-cr-00107-SPC-KRH     Document 21-1     Filed 12/20/21     Page 4 of 4 PageID 57

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