Supplemental Response to Standard Discovery Requests, United States v. Sean Patrick Boyd, Jr., Case 2:23-cr-00123
Summary
Document 21 in Case 2:23-cr-00123 is a September 26, 2023, Supplemental Response of the United States of America to the defendant's Standard Discovery Requests. It answers Request E by stating that the government will allow counsel for defendant to inspect any item of evidence, and that three SBA items are being provided: a Transcript of Account, a Certificate of Indebtedness, and a Certified Statement of Account. The filing repeats the request for reciprocal discovery within 14 days of service and the notice of intent to offer certified domestic records of regularly conducted activity. The signature line shows /s/ Jonathan T. Storage.
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Cite this document
“Supplemental Response to Standard Discovery Requests, United States v. Sean Patrick Boyd, Jr., Case 2:23-cr-00123.”
Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-wvsd-237310-21-0-b01f625b66/
, SHA-256 f83dff6965f53dfb2126b7384e7e1e7432df5f72acf2d0ab27d905f26b1c0216.Full text
Case 2:23-cr-00123 Document 21 Filed 09/26/23 Page 1 of 4 PageID #: 51
IN THE UNITED STATES DISTRICT COURT FOR THE
SOUTHERN DISTRICT OF WEST VIRGINIA
CHARLESTON
UNITED STATES OF AMERICA
v. CRIMINAL NO. 2:23-cr-00123
SEAN PATRICK BOYD, JR.
SEPTEMBER 26, 2023, SUPPLEMENTAL RESPONSE
OF THE UNITED STATES OF AMERICA TO DEFENDANT'S STANDARD
DISCOVERY REQUESTS, REQUEST OF THE UNITED STATES FOR RECIPROCAL
DISCOVERY, AND NOTICE OF THE UNITED STATES’S INTENT TO OFFER
EVIDENCE OF RECORDS OF REGULARLY CONDUCTED ACTIVITY
Pursuant to Rule 16 of the Federal Rules of Criminal
Procedure, Rule 16.1(a) of the Local Rules of Criminal Procedure,
and the Arraignment Order and Standard Discovery Request entered
by the Court in this case on September 8, 2023, the United States
of America, by counsel, herewith responds to each of defendant's
Standard Discovery Requests as follows:
Request E: Permit the defendant to inspect and to copy or
photograph books, papers, documents, data, photographs, tangible
objects, building or places, or copies or portions of any of those
items, if the item is within the government's possession, custody
or control, and (i) the item is material to preparing the defense;
(ii) the government intends to use the item in its case-in-chief
at trial; or (iii) the item was obtained from or belongs to
defendant. [Fed. R. Crim. P. 16(a)(1)(E)]
Response: The government will allow counsel for defendant to
inspect any item of evidence he deems appropriate. Counsel should
contact AUSA Jonathan T. Storage as soon as possible to arrange a
Case 2:23-cr-00123 Document 21 Filed 09/26/23 Page 2 of 4 PageID #: 52
mutually agreeable time to view the evidence. The following is
being provided:
BOYD-000437 SBA – Transcript of Account
BOYD-000438 SBA – Certificate of Indebtedness
BOYD-000439 SBA – Certified Statement of
Account
REQUEST OF THE UNITED STATES FOR RECIPROCAL DISCOVERY
Pursuant to Rules 16.1(b) and 16.1(d) of the Local Rules of
Criminal Procedure, the United States of America requests that
defendant provide all applicable reciprocal discovery within 14
days of the service of this response and the provision of materials
requested by defendant in the Standard Discovery Request.
NOTICE OF THE UNITED STATES INTENT TO OFFER
EVIDENCE OF RECORDS OF REGULARLY CONDUCTED ACTIVITY
Pursuant to Federal Rules of Evidence 902(11), notice is
hereby given of the United States intent to offer into evidence
certified domestic records of regularly conducted activity. The
records are referred to more specifically in Response E above.
2
Case 2:23-cr-00123 Document 21 Filed 09/26/23 Page 3 of 4 PageID #: 53
Respectfully submitted,
WILLIAM S. THOMPSON
United States Attorney
By:
/s/ Jonathan T. Storage
JONATHAN T. STORAGE
Assistant United States Attorney
WV Bar No. 12279
300 Virginia Street, East
Room 4000
Charleston, WV 25301
Telephone: 304-345-2200
Fax: 304-347-5704
Email: Jonathan.Storage@usdoj.gov
3
Case 2:23-cr-00123 Document 21 Filed 09/26/23 Page 4 of 4 PageID #: 54
CERTIFICATE OF SERVICE
It is hereby certified that the foregoing “SEPTEMBER 26, 2023,
SUPPLEMENTAL RESPONSE OF THE UNITED STATES OF AMERICA TO
DEFENDANT'S STANDARD DISCOVERY REQUESTS, REQUEST OF THE UNITED
STATES FOR RECIPROCAL DISCOVERY, AND NOTICE OF THE UNITED STATES’S
INTENT TO OFFER EVIDENCE OF RECORDS OF REGULARLY CONDUCTED
ACTIVITY” has been electronically filed and service has been made
on opposing counsel by virtue of such electronic filing this 26th
day of September , 2023 to:
Emily L. Szopinski, Assistant Federal Public Defender
Robert C. Byrd United States Courthouse
300 Virginia Street, East, Suite 3400
Charleston, West Virginia 25301
/s/Jonathan T. Storage
JONATHAN T. STORAGE
Assistant United States Attorney
WV Bar No.12279
300 Virginia Street, East
Room 4000
Charleston, WV 25301
Telephone: 304-345-2200
Fax: 304-347-5704
Email:Jonathan.Storage@usdoj.gov
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