Professional Documents
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The government has produced automatic discovery. To date, the government has
produced to the defendant discovery in 1378 pages, along with disks and a hard drive of media
and other evidence.
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according to the Local Rules and pursuant to the Federal Rules of Criminal Procedure, including
any supplemental discovery if any additional materials are obtained.
3.
The Court has ordered that the deadline for the defendant to file discovery
requests be postponed until after the government decides whether to seek additional charges
against him.
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A protective order has been agreed to by the parties and entered by the Court. See
5.
The parties agree that the scheduling of Fed. R. Crim. P. 12(b) motions at this
time is premature.
6.
The parties agree that expert witness disclosures are premature. Concerning the
pending firearms and assault charges, the government will call a firearms expert to discuss the
firearms seized from the defendant.
7.
The parties agree that all of the time from May 24, 2016 to the date of the next
status conference should be excluded under the Speedy Trial Act, 18 U.S.C. 3161(h)(7). The
parties agree that the ends of justice served by excluding the time from the Speedy Trial Act,
outweigh the best interests of the public and defendant in a speedy trial. The parties agree that
this Speedy Trial Act exclusion is appropriate in order to allow: (1) the government time to
consider presenting a superseding indictment to the grand jury that would significantly alter the
prosecution and defense of the case, (2) defense counsel to review the discovery with the
defendant, and (3) the defendant to consider his options in light of the evidence. A proposed
order of excludable delay is attached.
9.
The parties have not yet engaged in plea discussions. The estimated length of
trial is 4 weeks.
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Respectfully submitted,
CARMEN M. ORTIZ
UNITED STATES ATTORNEY
By:
By:
Certificate of Service
June 7, 2016
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 (NEF).
/s/ Deepika B. Shukla
Deepika B. Shukla
Assistant United States Attorney
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______________________
Katherine A. Robertson
United States Magistrate Judge