Joint Report re: Discovery Conference, United States v. Andrew Marnell (C.D. Cal.), Dkt. 27

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A joint report regarding the discovery conference in United States v. Andrew Marnell, No. CR 20-319-RGK, in the U.S. District Court for the Central District of California, filed August 14, 2020 as Document 27, with trial set for September 29, 2020. AUSA Kerry L. Quinn and Deputy Federal Public Defender Adithya Mani report that they conducted the conference by teleconference on August 13, 2020 and have identified no contested discovery matters or chain of custody objections. The report states that the government has produced approximately 4,500 pages, including agent reports, bank and financial records, casino records and recordings from the defendant's arrest on July 16, 2020, and acknowledges its obligations under Brady v. Maryland.

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NICOLA T. HANNA 
Acting United States Attorney 
BRANDON D. FOX 
Assistant United States Attorney 
Chief, Criminal Division 
KERRY L. QUINN (Cal. Bar No. 302954) 
Assistant United States Attorney 
Major Frauds Crimes Section 
312 North Spring Street, 11th Floor 
Los Angeles, California 90012 
Telephone: (213) 894-5423 
Facsimile: (213) 894-6269 
E-mail: 
Kerry.L.Quinn@usdoj.gov 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
 
UNITED STATES DISTRICT COURT 
 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
ANDREW MARNELL, 
 
Defendant. 
No. CR 20-319-RGK 
JOINT REPORT RE: DISCOVERY 
CONFERENCE 
Trial Date: September 29, 2020 
Trial Time: 9:00 a.m. 
Location:   Courtroom of the  
           Hon. R. Gary Klausner  
 
 
Plaintiff United States of America, by and through its counsel 
of record, the United States Attorney for the Central District of 
California and Assistant United States Attorney (“AUSA”) Kerry L. 
Quinn, and defendant Andrew Marnell (“defendant”), by and through his 
counsel of record, Deputy Federal Public Defender (“DFPD”) Adithya 
Mani, hereby report the following, pursuant to the Court’s Criminal 
Order Regarding Discovery (the “Court’s Standing Discovery Order”): 
(a) 
On August 13, 2020, the parties conducted a discovery 
conference pursuant to the Court’s Standing Discovery Order.  AUSA 
Quinn and DFPD Mani participated in the conference, which was 
conducted by way of teleconference on August 13, 2020.  The parties 
Case 2:20-cr-00319-RGK     Document 27     Filed 08/14/20     Page 1 of 3   Page ID #:168

 
 
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have had ongoing discussions regarding discovery in this case, dating 
back to defendant’s arrest on July 16, 2020. 
(b) 
The parties have not presently identified any contested 
matter of discovery and inspection, but each party reserves the right 
to raise issues as they arise.  The government has produced 
approximately 4,500 pages of documents and files as part of discovery 
in this case, which includes agent reports, bank and other financial 
records, records from casinos, surveillance photos, search and 
seizure warrants and related documents, recordings from defendant’s 
arrest, records from state taxing authorities, and criminal history 
reports, among other documents and files.  The government’s 
investigation is ongoing, and it anticipates producing additional 
discovery on a rolling basis.   
(c) 
The government is aware of its obligations to produce 
material favorable to defendant within the meaning of Brady v. 
Maryland, 373 U.S. 83 (1963) and related cases, and it has complied 
with and will continue to comply with these obligations.   
(d) 
The parties have not presently identified any foundational 
or chain of custody objections to evidence that may be offered at 
trial, but each party reserves the right to make such objections as 
warranted. 
(e) 
The discovery in this case does not presently include any 
evidence that requires scientific analysis, but if either party 
identifies any such evidence, the parties will confer about the  
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Case 2:20-cr-00319-RGK     Document 27     Filed 08/14/20     Page 2 of 3   Page ID #:169

 
 
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possibility of resolving the admissibility of the scientific analysis 
without the need to call an expert to testify at trial. 
 
Dated: August 14, 2020 
Respectfully submitted, 
 
NICOLA T. HANNA 
United States Attorney 
 
BRANDON D. FOX 
Assistant United States Attorney 
Chief, Criminal Division 
 
 
 /s/ Kerry L. Quinn         
 
KERRY L. QUINN 
Assistant United States Attorney 
 
Attorneys for Plaintiff 
UNITED STATES OF AMERICA 
 
 
 
 
Dated: August 14, 2020 
 
 
 
  /s/ by email authorization 
 
ADITHYA MANI 
Deputy Federal Public Defender 
 
Attorney for Defendant 
ANDREW MARNELL 
 
 
Case 2:20-cr-00319-RGK     Document 27     Filed 08/14/20     Page 3 of 3   Page ID #:170

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