USA v. Trump, et al. Document 362: Response to Standing Discovery Order

Florida Southern District Court
Case No. 9:23-cr-80101-AMC
Filed March 4, 2024

Supplemental RESPONSE to Standing Discovery Order by USA as to Donald J. Trump, Waltine Nauta, Carlos De Oliveira (Edelstein, Julie)

BackBack to USA v. Trump, et al.

Tags No tags have been applied so far. Sign in to add some.

  Formatted Text Tab Overlap Raw Text Right End
Page 1 Case 9:23-cr-80101-AMC Document 362 Entered on FLSD Docket 03/04/2024 Page 1 of
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
WEST PALM BEACH DIVISION
CASE NO. 23-80101-CR-CANNON(s)
UNITED STATES OF AMERICA,
Plaintiff,
v.
DONALD J. TRUMP,
WALTINE NAUTA, and
CARLOS DE OLIVEIRA,
Defendants.
______________________________/
GOVERNMENT’S SUPPLEMENTAL RESPONSE
TO STANDING DISCOVERY ORDER
The United States of America, by and through the Special Counsel’s Office, files this
pleading to supplement prior responses (ECF Nos. 30, 59, 80, 92, 113, 122, 143, 172, 184, 190,
199, 204, 235, 253, 273, 291, 330) to the Standard Discovery Order, issued on June 13, 2023 (ECF
No. 16). This pleading complies with Local Rule 88.10 and Federal Rule of Criminal Procedure
16.
Per the protective order issued in this case (ECF No. 27), the Government has provided
twelve prior productions of unclassified discovery to Defendants Donald J. Trump, Waltine Nauta,
and Carlos De Oliveira.
See ECF Nos. 30, 59, 80, 92, 113, 122, 143, 172, 184, 235, 253, 273,
291, 330. On March 4, 2024, the Government provided a thirteenth production of unclassified
discovery to counsel for Defendants (“Production 13”).
Production 13 consists of approximately
Page 2 Case 9:23-cr-80101-AMC Document 362 Entered on FLSD Docket 03/04/2024 Page 2 of
78 pages and includes two items: (1) the warrant application for an account associated with
Defendant Nauta,1 and (2) memorialization of an interview conducted on February 9, 2024.
The Government responds to the specific items identified in the standing discovery order
as set forth below.
B.
DEMAND FOR RECIPROCAL DISCOVERY: The United States requests the
disclosure and production of those items described and listed in paragraph B of the
Standing Discovery Order, and as provided by Federal Rule of Criminal Procedure
16(b).
C.
The Government is providing information or material known to the United States
that may be favorable to either defendant on the issues of guilt or punishment within
the scope of Brady v. Maryland, 373 U.S. 83 (1963), or United States v. Agurs, U.S. 97 (1976).
D.
The Government has disclosed and will continue to 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).
J.
The Government’s discovery productions include the grand jury testimony and
recordings of witnesses who may testify for the Government at the trial of this case.
The Government is aware of its continuing duty to disclose 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.
Respectfully submitted,
JACK SMITH
Special Counsel
By:
/s/ Jay I. Bratt
Jay I. Bratt

A redacted version is available online, see ECF No. 359 at 7 n.1 (citing In re Sealed Search
Warrant, No. 9:22-mj-08550-BER (Aug. 28, 2023)), but the unredacted version was inadvertently
not previously produced in discovery. The search warrant returns and property receipt were
previously produced in discovery.
Page 3 Case 9:23-cr-80101-AMC Document 362 Entered on FLSD Docket 03/04/2024 Page 3 of
Counselor to the Special Counsel
Special Bar ID #A950 Pennsylvania Avenue, NW
Washington, D.C. Julie A. Edelstein
Senior Assistant Special Counsel
Special Bar ID #ADavid V. Harbach, II
Assistant Special Counsel
Special Bar ID #A
Page 4 Case 9:23-cr-80101-AMC Document 362 Entered on FLSD Docket 03/04/2024 Page 4 of
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on March 4, 2024, I electronically filed the foregoing document
with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
served this day on all counsel of record via transmission of Notices of Electronic Filing generated
by CM/ECF.
/s/ Julie A. Edelstein
Julie A. Edelstein
Senior Assistant Special Counsel
Space
Issues Laws Cases Pro Articles Firms Entities
Issues Laws Cases Pro Articles Firms Entities
 
PlainSite
Sign Up
Need Password Help?