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Government’s Response to the Standing Discovery Order — United States v. Grenon (Dkt. 60, S.D. Fla.)

Summary

The Government's Response to the Standing Discovery Order in United States of America v. Joseph Timothy Grenon, Case No. 21-20242-CR-ALTONAGA/TORRES, in the U.S. District Court for the Southern District of Florida, served January 13, 2022 under Local Rule 88.10 and Federal Rule of Criminal Procedure 16. The government states that it knows of no oral statements by the defendant to known government agents that it intends to use, and that recordings of his statements, his prior criminal record and documents it intends to use at trial have been provided by separate mailing. It states that no defendant testified before the Grand Jury. Assistant United States Attorney Michael B. Homer certifies service by mail on the pro se defendant.

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Filed January 13, 2022 in Joseph Timothy Grenon; one of 22 filings from this case.

Record facts

Court	U.S. District Court for the Southern District of Florida
Filed	2022-01-13

Cite this document

“Government’s Response to the Standing Discovery Order — United States v. Grenon (Dkt. 60, S.D. Fla.).” U.S. District Court for the Southern District of Florida, No. 1:21-cr-20242, Doc. 60, filed 2022-01-13. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/us-v-mark-scott-grenon/2022-01-13-government-s-response-to-the-standing-discovery-order-dkt-60/, SHA-256 816475d581082f7f82ffd5f463bb8489d3a70aa9e25831fe84579f406eed9543.

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Full text

Case 1:21-cr-20242-CMA Document 60 Entered on FLSD Docket 01/13/2022 Page 1 of 4

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. 21-20242-CR-ALTONAGA/TORRES

UNITED STATES OF AMERICA,

JOSEPH TIMOTHY GRENON,

Defendant.
/

GOVERNMENT=S RESPONSE TO
THE STANDING DISCOVERY ORDER

The United States hereby files this response to the Standing Discovery Order. This

response also complies with Local Rule 88.10 and Federal Rule of Criminal Procedure 16, and is

numbered to correspond with Local Rule 88.10.

A. 1. The government is unaware of any oral statements made by the Defendant
before or after arrest in response to interrogation by any person then known
to the Defendant to be a government agent that the government intends to
use at trial.

2. Copies of audio and video tapes which contain recordings of statements
made by the Defendant have been provided to the Defendant by separate
mailing.

3. No defendant testified before the Grand Jury.

4. The prior criminal record of the Defendant has been provided to the
Defendant by separate mailing.

5. Books, papers, documents, photographs, tangible objects, buildings or
places which the government intends to use as evidence at trial to prove its
case in chief, or were obtained or belonging to the Defendant, have been
provided to the Defendant by separate mailing to the extent practicable, but
not filed with the Court. Other items, including additional items that may
become available at a later date, may be inspected at a mutually convenient
time by making arrangements with the undersigned Assistant United States

Case 1:21-cr-20242-CMA Document 60 Entered on FLSD Docket 01/13/2022 Page 2 of 4

Attorneys, who will facilitate such inspection with the United States
Marshals Service.

The materials referenced in this discovery response are not necessarily
copies of all the books, papers, documents, etc., that the government may
intend to introduce at trial.

6. A laboratory analysis report regarding the substances seized in connection
with this case, including substances labeled “Sacramental Cleansing
Powder” and “Sacramental Cleansing Water,” has been provided to the
Defendant by separate mailing.

B. DEMAND FOR RECIPROCAL DISCOVERY: The United States requests
the disclosure and production of materials enumerated as items 1 and 2 of
Section B of the Standing Discovery Order. This request is also made
pursuant to Rule 16(b) of the Federal Rules of Criminal Procedure.

C. The government will disclose any information or material which may be
favorable on the issues of guilt or punishment within the scope of Brady v.
Maryland, 373 U.S. 83 (1963), and United States v. Agurs, 427 U.S. 97
(1976).

D. The government will disclose any payments, promises of immunity,
leniency, preferential treatment, or other inducements made to prospective
government witnesses, within the scope of Giglio v. United States, 405 U.S.
150 (1972), or Napue v. Illinois, 360 U.S. 264 (1959).

E. The government will disclose any prior convictions of any alleged co-
conspirator, accomplice or informant who will testify for the government at
trial.

F. No defendant was identified in a lineup, show up, photo spread or similar
identification proceedings.

G. The government has advised its agents and officers involved in this case to
preserve all rough notes.

H. The government will timely advise the Defendant of its intent, if any, to
introduce during its case in chief proof of evidence pursuant to F.R.E.
404(b). The Defendant is hereby on notice that all evidence made
available for inspection, as well as all statements disclosed herein or in any
future discovery letter, may be offered in the trial of this cause, under F.R.E.
404(b) or otherwise (including the inextricably-intertwined doctrine).

Case 1:21-cr-20242-CMA Document 60 Entered on FLSD Docket 01/13/2022 Page 3 of 4

I. The Defendant is not an aggrieved person, as defined in Title 18, United
States Code, Section 2510(11), of any electronic surveillance.

J. The government has ordered transcribed the Grand Jury testimony of all
witnesses who will testify for the government at the trial of this cause.

K. No controlled substance is involved in this indictment.

L. The government does not know of any automobile, vessel, or aircraft
allegedly used in the commission of this offense that is in the government's
possession.

M. The government is not aware of any latent fingerprints or palm prints which
have been identified by a government expert as those of the Defendant.

N. The government will make every possible effort in good faith to stipulate to
all facts or points of law the truth and existence of which is not contested
and the early resolution of which will expedite trial.

O. The government is available for a pretrial discovery conference as required
by Rule 16.1 of the Federal Rules of Criminal Procedure and Local Rule
88.10(o).

The government is aware of its continuing duty to disclose such newly discovered
additional information required by the Standing Discovery Order, Rule 16(c) of the Federal Rules
of Criminal Procedure, Brady, Giglio, Napue, and the obligation to assure a fair trial.

[THIS SPACE INTENTIONALLY LEFT BLANK]

Case 1:21-cr-20242-CMA Document 60 Entered on FLSD Docket 01/13/2022 Page 4 of 4

Discovery materials referenced in this response numbered GOV01-000001 through
GOV01-110989 have been provided to the Defendant by separate mailing. Discovery materials
referenced in this response numbered GOV01-110990 through GOV01-117595 and SWGR-
00000001 through SWGR-00702566 will be provided to the Defendant by separate mailing
shortly, upon receipt by the government of an external hard drive with sufficiently large storage
capacity to allow for the storage of such discovery materials.

Respectfully submitted,

JUAN ANTONIO GONZALEZ
UNITED STATES ATTORNEY

BY: /s/ Michael B. Homer
MICHAEL B. HOMER
Assistant United States Attorney
Court ID No. A5502497
99 Northeast 4th Street
Miami, Florida 33132-2111
Tel: (305) 961-9289
Michael.Homer@usdoj.gov

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on January 13, 2022, I caused a true and correct copy of the

foregoing, and the discovery materials referenced therein, to be delivered via Certified Mail to pro

se Defendant Joseph Timothy Grenon at the Miami Federal Detention Center, Inmate Mail/Parcels,

Post Office Box 019120, Miami, Florida 33101.

/s/ Michael B. Homer
MICHAEL B. HOMER
Assistant United States Attorney

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