Eleventh Certificate of Compliance and Request for Reciprocal Discovery — United States v. Baver (Dkt. 247, D. Utah)

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The government's Eleventh Certificate of Compliance and Request for Reciprocal Discovery in United States of America v. Allison Marie Baver and Allison Baver Entertainment, LLC, Case No. 2:21cr00520 - JNP, in the U.S. District Court for the District of Utah, filed October 28, 2024. The United States certifies that all discovery previously provided to defense counsel is being provided to new counsel of record through USAfx. It gives notice under Rule 12(b)(4)(A) of the Federal Rules of Criminal Procedure that it may seek to use at trial the physical evidence and statements described, and it requests reciprocal discovery from the defendant. The certificate of service lists new counsel Michael J. Langford and Alexander E. Ramos.

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Case 2:21-cr-00520-JNP Document 247 Filed 10/28/24 PageID.3745 Page 1 of 4




TRINA A. HIGGINS, United States Attorney (#7349)
CY H. CASTLE, Assistant United States Attorney (#4808)
Attorneys for the United States of America
Office of the United States Attorney
111 South Main Street, Suite 1800
Salt Lake City, Utah 84111-2176
Telephone: (801) 524-5682

                          IN THE UNITED STATES DISTRICT COURT
                                       DISTRICT OF UTAH


  UNITED STATES OF AMERICA,                         Case No. 2:21cr00520 - JNP

          Plaintiff,                                      ELEVENTH CERTIFICATE OF
                                                        COMPLIANCE AND REQUEST FOR
          vs.                                              RECIPROCAL DISCOVERY

  ALLISON MARIE BAVER, AND
  ALLISON BAVER ENTERTAINMENT,
  LLC,                                              Judge Jill N. Parrish

          Defendants.


       The United States of America, by and through the undersigned, hereby files its eleventh

certificate of compliance with its discovery obligations in this case and request for reciprocal

discovery from the defendant.

       The United States gives notice that the following is being or has been provided to counsel

for the defendant:

                                            Description

 All discovery previously provided to Defendants’ counsel is being provided to new counsel of
 record via USAfx (NOC 11)


       Pursuant to Rule 12(b)(4)(A) of the Federal Rules of Criminal Procedure, the United

States notified the defense that at trial, the United States may seek to use all physical evidence,

statements made by the defendant and others, police reports, phone records, electronic evidence

 Case 2:21-cr-00520-JNP Document 247 Filed 10/28/24 PageID.3746 Page 2 of 4




(including body camera footage), documents, and photographs obtained during the investigation.

The United States reserves the right to introduce in its case-in-chief all tangible objects, physical,

documentary, and electronic evidence, and all other evidence provided, made available, or

identified in discovery.

       As additional discoverable material becomes available, such material will be provided

within a reasonable time. Throughout this case, the United States will provide material

discoverable under Rules 16 and 26.2 of the Federal Rules of Criminal Procedure and the Jencks

Act without requiring the defendant to make a specific request for such material. Upon the

request of the defendant, the United States will permit and facilitate the defendant’s own

inspection, copying or photographing of those items described/defined in Rule 16(a)(1)(E).

       The United States also hereby requests disclosure of evidence by the defendant (also

known as reciprocal discovery) pursuant to Rule 16(b) of the Federal Rules of Criminal

Procedure and DUCrimR 16-1(c). By providing Rule 16 discovery without requiring a specific

request from the defense, the United States invokes a reciprocal obligation on the defendant

under DUCrimR 16-1(c), which states that the defendant must allow the government to inspect

and to copy the following, as further defined in Rule 16 of the Federal Rules of Criminal

Procedure:

               a.      Documents and tangible objects the defendant intends to introduce as

                       evidence at trial;

               b.      Reports of examinations and tests the defendant intends to introduce at

                       trial or that were prepared by a witness whom the defendant intends to call

                       at trial; and




                                                  2

 Case 2:21-cr-00520-JNP Document 247 Filed 10/28/24 PageID.3747 Page 3 of 4




               c.      A written summary of the testimony of any expert the defendant intends to

                       use a trial under Federal Rules of Evidence 702, 703 and 705.

The United States requests that the defendant provide to the government at a reasonable time

before trial, but no later than five working days before trial, copies of the material referenced in

this paragraph. Further, the United States requests continuing compliance with the reciprocal

discovery following the initial disclosure.

       The United States also hereby requests all written and recorded statements by any witness

other than the defendant whom the defendant intends to call at trial or a hearing covered by the

Jencks Act or Rule 26.2 of the Federal Rules of Criminal Procedure.

       DATED this 28th day of October, 2024.

                                               TRINA A. HIGGINS
                                               United States Attorney


                                               /s/Trina A. Higgins
                                               TRINA A. HIGGINS




                                                  3

 Case 2:21-cr-00520-JNP Document 247 Filed 10/28/24 PageID.3748 Page 4 of 4




                               CERTIFICATE OF SERVICE

       I certify that on the 28th day of October, 2024, the ELEVENTH CERTIFICATE OF

COMPLIANCE AND REQUEST FOR RECIPROCAL DISCOVERY was filed electronically to

the District Court, and caused to be made available for download from USAfx, to the following:

Michael J. Langford
Alexander E. Ramos
admin@langfordramos.com

Julia Frys
Juliafrys19@gmail.com




                                           Christine Allred
                                           Secretary to the U.S. Attorney




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