Court filing

Government’s Proposed Trial Deadlines — United States v. Dessaps (Dkt. 105, D. Mass.)

Summary

The government's proposed trial deadlines in United States v. Bill Dessaps, No. 24-CR-10009-AK, in the U.S. District Court for the District of Massachusetts, filed March 13, 2025 as Dkt. 105 by Assistant U.S. Attorney David M. Holcomb. It states that the trial was moved at a February 4 status conference to September 8 and asked for a revised scheduling order (Dkt. 101). The government proposes deadlines consistent with the earlier order (Dkt. 89) except for its non-witness disclosures, asking for a seven-week deadline for witness disclosures, as the defendant originally requested, and a three-week deadline for other disclosures, as both parties proposed earlier. It notes the defendant now seeks seven weeks for all disclosures (Dkt. 104).

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Filed March 13, 2025 in Bill Dessaps; one of 2 filings from this case.

Record facts

Court	U.S. District Court for the District of Massachusetts
Filed	2025-03-13

Cite this document

“Government’s Proposed Trial Deadlines — United States v. Dessaps (Dkt. 105, D. Mass.).” U.S. District Court for the District of Massachusetts, No. 1:24-cr-10009, Doc. 105, filed 2025-03-13. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-bill-dessaps/2025-03-13-government-s-proposed-trial-deadlines-dkt-105/, SHA-256 7c2df12e4f28c6e7a44611b0e2946824126ef05ad059e67b8489b4c1041780d2.

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Full text

Case 1:24-cr-10009-AK Document 105 Filed 03/13/25 Page 1 of 6

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

)
UNITED STATES OF AMERICA, )
Plaintiff, )
) No. 24-CR-10009-AK
)
v. )
)
BILL DESSAPS, )
Defendant. )
)

Government’s Proposed Trial Deadlines

At the status conference on February 4, the Court rescheduled the trial in this case to begin

on September 8 and instructed the parties to submit a revised scheduling order. Dkt. 101.

The government respectfully proposes the deadlines outlined below. These deadlines are

generally consistent with the Court’s previous scheduling order (Dkt. 89), except with respect to

the government’s non-witness disclosures. When the parties first proposed pretrial deadlines

ahead of a February 24 trial date, the defendant requested an earlier deadline for the government’s

witness disclosure (seven weeks before trial), but the parties otherwise jointly proposed that all

other government disclosures be made three weeks before trial. Dkt. 88. However, the Court’s

subsequent scheduling order adopted a seven-week deadline for all government disclosures. Dkt.

89. The government respectfully requests that, in resetting the deadlines, the Court adopt the

seven-week deadline for witness disclosures only (as originally requested by the defendant) and

the three-week deadline for other disclosures (as previously proposed by both parties).1

1
The defendant now requests a seven-week deadline for all government disclosures. Dkt.
104. The defendant has offered no sound basis for asking that the government be required to make
all of its disclosures, including exhibits and witness statements, so unusually far in advance of trial.

Case 1:24-cr-10009-AK Document 105 Filed 03/13/25 Page 2 of 6

I. Trial Deadlines:

A. Government’s Witness Disclosure: On or before Monday, July 21, 2025, the

government shall disclose to the defendant a list of prospective witnesses the government

may call during its case-in-chief, identified by city or town of residence.

B. Government’s Other Disclosures: On or before August 11, 2025, the government shall

disclose to the defendant:

1. Exculpatory Information: any and all exculpatory information identified in Local

Rule 116.2 that has not been previously produced;

2. “Prior Bad Acts” Evidence: a general description, including the approximate date,

time, and place, of any “prior bad acts” evidence the government plans to introduce

under Fed R. Evid. 404(b);

3. Witness Statements: any statement, as contemplated by 18 U.S.C § 3500(e) and Fed.

R. Crim. P. 26.2, of a witness that the government may call during its case-in-chief;

and,

4. Exhibits: copies of any exhibits and a premarked list of exhibits the government may

introduce during its case-in-chief.

C. Defendant Disclosures: On or before Monday, August 18, 2025, the defendant shall

disclose to the government:

1. Witnesses: a list of prospective witnesses the defense may call during its case-in-

chief, identified by city or town of residence;

2. Witness Statements: any statement, as contemplated by 18 U.S.C § 3500(e) and Fed.

R. Crim. P. 26.2, of a witness that the defense may call during its case-in-chief; and

3. Exhibits: copies of any exhibits and a premarked list of exhibits the defense may

Case 1:24-cr-10009-AK Document 105 Filed 03/13/25 Page 3 of 6

introduce during its case-in-chief.

D. Continuing Disclosure Obligation: After completing these disclosures, the parties shall

be under a continuing obligation to timely disclose any additional witnesses or exhibits

that they subsequently develop an intent to call or offer. The government shall make

every effort to disclose all relevant information as early as possible. The Court will not

tolerate late disclosures without good cause shown.

II. PRETRIAL FILINGS

A. Motions in Limine: On or before Wednesday, August 20, 2025, the parties shall file any

motions in limine or other requests regarding foreseeable disputes concerning evidentiary

issues, including memoranda providing authority for the ruling requested.

• Oppositions are due by August 26, 2025. Parties shall confer prior to filing any

motions in limine to narrow the issues presented to the Court.

B. Voir Dire Questions and Jury Instructions: On or before Monday, August 18, 2025, the

parties shall, jointly or separately, file with the Court any proposed questions for the voir

dire examination and any proposed substantive jury instructions, with citation to

supporting authority, though the parties need not submit boilerplate preliminary or post-

trial instructions.

• Oppositions: On or before Monday, August 25, 2025, file any objections to the

other party’s proposed voir dire questions and jury instructions. The parties shall

clearly indicate voir dire questions and jury instructions to which there are no

objections and any voir dire questions and jury instructions that are contested. If

the objections include proposed modifications of the other party’s any voir dire

questions and jury instructions, such proposed modifications shall be presented

Case 1:24-cr-10009-AK Document 105 Filed 03/13/25 Page 4 of 6

using underlining (for proposed additions) and strike-out (for proposed deletions).

• Editable Versions of the Filings: The parties shall send editable Word versions of

these filings to the Deputy Clerk on the same date the documents are filed with

the Court.

C. Trial Briefs: On or before Monday, August 25, 2025, each party shall file a trial brief

forth any and all remaining or foreseeable disputes concerning issues of law.

D. Final Pretrial Filings: On or before Monday, August 25, 2025, the parties shall file with

the Court each of the following:

1. Stipulated Facts: any stipulated or admitted facts that the parties agree are not

in dispute in a form suitable for presentation to the jury;

2. Witnesses: a list of prospective witnesses to be brought to the jury’s attention

during voir dire, identified by city or town of residence, to be sent by email to

the Deputy Clerk and not filed on the public docket;

3. Rule 16 Statements: a statement of the qualifications of any prospective

government expert witness, any summary of prospective government witness

testimony that has been produced to the defendant pursuant to Fed. R. Crim. P.

16(a)(1)(G), and any reciprocal disclosure produced by the defendant pursuant

to Fed. R. Crim. P. 16(b)(1)(C);

4. Technology Requests: any request to use audio-visual equipment or other

courtroom technology during trial;

5. Estimate of Length: an informed estimate of the length of the trial, based on a

schedule of 9:00 AM to 1:00 PM, Monday through Friday; and

6. Exhibits: a joint list of (a) “Uncontested Exhibits,” i.e., photographs,

Case 1:24-cr-10009-AK Document 105 Filed 03/13/25 Page 5 of 6

documents, instruments, and all other objects, as to which there appear to be

no objections, identified and marked by a single sequence of numbers

regardless of which party is the proponent, in the form attached hereto as

Appendix A, and (b) a list of “Exhibits to be Offered at Trial” of exhibits to

which each party reserves the right to object, identified and marked by the

party proponent and a separate sequence of capital letters for each party, i.e.

Government A-Z and Defendant(s) A-Z, in the form attached hereto as

Appendix A.

E. Courtesy Copies (Electronic): On the same date the exhibit lists are filed with the

Court, the parties shall provide the Court with a disc containing courtesy copies of all

exhibits, labeled according to the sequences described above.

F. Courtesy Copies (Paper): At least one business day before trial, counsel shall provide

the Court with 3 paper courtesy copies of all exhibits. The exhibits shall be pre-marked

with exhibit stickers containing the exhibit number or letter set forth in the joint list of

exhibits, and should have extraneous prior exhibit numbers, exhibit stickers, or other

numbering removed. If counsel plan to place paper copies of exhibits on the witness

stand, counsel should ensure that they come prepared with enough copies of exhibits for

both the testifying witness and the examining attorney.

Respectfully submitted,

LEAH B. FOLEY
United States Attorney

/s/ David M. Holcomb s
David M. Holcomb
Meghan Chambers Cleary
Assistant United States Attorneys

Case 1:24-cr-10009-AK Document 105 Filed 03/13/25 Page 6 of 6

CERTIFICATE OF SERVICE

I hereby certify that this document, filed through the ECF system will be sent electronically
to the registered participants as identified on the Notice of Electronic Filing.

Dated: March 13, 2025

/s/ David M. Holcomb
DAVID M. HOLCOMB
Assistant U.S. Attorney

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