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Unopposed Motion to Send Voluminous Discovery Via External Thumb Drive — No. 4:23-cr-00067 (Dkt. 27, W.D. Mo.)

Summary

Unopposed Motion to Send Voluminous Discovery Via External Thumb Drive, Document 27 in Case 4:23-CR-00067-BP-1 in the Western District of Missouri, Kansas City Division, dated October 12, 2023 and filed 10/17/23 by defence counsel in Chicago. Counsel states that discovery is extremely voluminous, that paper copies mailed in September 2023 to USP Leavenworth in Kansas, where the defendant is housed, were rejected by the facility for unknown reasons, and that counsel cannot travel to review discovery in person in a timely fashion. He therefore asks permission to load the discovery onto an external thumb drive and mail it to the defendant. The government does not oppose, and a certificate of service is dated October 17, 2023.

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Cite this document

“Unopposed Motion to Send Voluminous Discovery Via External Thumb Drive — No. 4:23-cr-00067 (Dkt. 27, W.D. Mo.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/unopposed-motion-to-send-voluminous-discovery-via-external-thumb-drive-cd01e4d37a/, SHA-256 34cbbb81584f17a0e1698af5f30a3cb6db59b2afdb9766ba9d51eefb60f20665.

Full text

                      IN THE UNITED STATES DISTRICT COURT
                     FOR THE WESTERN DISTRICT OF MISSOURI
                              KANSAS CITY DIVISION

UNITED STATES OF AMERICA                     )
                                             )
       v.                                    )       4:23-CR-00067-BP-1
                                             )
MIRZA M. REAZUDDIN                           )


  UNOPPOSED MOTION TO SEND VOLUMINOUS DISCOVERY VIA EXTERNAL
                         THUMB DRIVE

       Mr. Sami Azhari of Azhari, LLC, the law firm representing Mirza Reazuddin,

respectfully moves this Court to allow him to send voluminous discovery materials to Mr.

Reazuddin via external thumb drive, and states the following:

   1. Discovery in this matter is extremely voluminous.

   2. Undersigned counsel attempted to send paper copies of discovery to Mr. Reazuddin via

       United States Postal Service in September 2023, to USP Leavenworth in Kansas, where

       he is currently housed, but this delivery was rejected by the facility for reasons unknown

       to undersigned counsel.

   3. Undersigned counsel is located in Chicago, Illinois and unable to meet with Mr.

       Reazuddin in person to review discovery in a timely fashion.

   4. To ensure that Mr. Reazuddin is able to review discovery in a timely fashion,

       undersigned counsel respectfully requests permission to load discovery onto an external

       thumb drive and mail to Mr. Reazuddin.

   5. The Government does not oppose this Motion.




                                            Page 1 of 3

            Case 4:23-cr-00067-BP Document 27 Filed 10/17/23 Page 1 of 3
       WHEREFORE, undersigned counsel, Sami Azhari, respectfully requests that this Court

grant his request to allow him to send discovery materials to Mr. Reazuddin via external thumb

drive, and for such other and further relief as is appropriate under the circumstances.

       October 12, 2023                               Respectfully Submitted,




                                              /s/Sami Azhari
                                              Sami Azhari, attorney for Mirza Reazuddin



       Sami Azhari
       Azhari LLC
       134 North Lasalle Street
       Suite 444
       Chicago, Illinois 60602
       Phone: (312) 626-2871
       Email: sazhari@azharillc.com
       Attorney No: 6294661




                                             Page 2 of 3

           Case 4:23-cr-00067-BP Document 27 Filed 10/17/23 Page 2 of 3
                               CERTIFICATE OF SERVICE

The undersigned states that, on October 17, 2023, he caused the above to be served on
counsel of record by way of ECF filing.

                                            Respectfully submitted,

                                            /s/Sami Azhari
                                            Sami Azhari

                                            Attorney for Mirza Reazuddin




                                           Page 3 of 3

          Case 4:23-cr-00067-BP Document 27 Filed 10/17/23 Page 3 of 3

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