Page 1 Case 9:23-cr-80101-AMC Document 371 Entered on FLSD Docket 03/07/2024 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, 362) to the Standard Discovery Order, issued on June 13, (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
thirteen prior productions of unclassified discovery to Defendants Donald J. Trump, Waltine
Nauta, and Carlos De Oliveira.
273, 291, 330, 362.
See ECF Nos. 30, 59, 80, 92, 113, 122, 143, 172, 184, 235, 253,
On March 7, 2024, the Government provided a fourteenth production of
unclassified discovery to counsel for Defendants (“Production 14”).
Production 14 consists of
nine pages and includes the memorialization of an interview conducted on March 6, 2024.Page 2 Case 9:23-cr-80101-AMC Document 371 Entered on FLSD Docket 03/07/2024 Page 2 of
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
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 #A Page 3 Case 9:23-cr-80101-AMC Document 371 Entered on FLSD Docket 03/07/2024 Page 3 of
David V. Harbach, II
Assistant Special Counsel
Special Bar ID #A Page 4 Case 9:23-cr-80101-AMC Document 371 Entered on FLSD Docket 03/07/2024 Page 4 of
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on March 7, 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
PDF Page 1
PlainSite Cover Page
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Case 9:23-cr-80101-AMC Document 371 Entered on FLSD Docket 03/07/2024 Page 1 of 4
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, 362) 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
thirteen prior productions of unclassified discovery to Defendants Donald J. Trump, Waltine
Nauta, and Carlos De Oliveira.
273, 291, 330, 362.
See ECF Nos. 30, 59, 80, 92, 113, 122, 143, 172, 184, 235, 253,
On March 7, 2024, the Government provided a fourteenth production of
unclassified discovery to counsel for Defendants (“Production 14”).
Production 14 consists of
nine pages and includes the memorialization of an interview conducted on March 6, 2024.
PDF Page 3
Case 9:23-cr-80101-AMC Document 371 Entered on FLSD Docket 03/07/2024 Page 2 of 4
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, 427
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
Counselor to the Special Counsel
Special Bar ID #A5502946
950 Pennsylvania Avenue, NW
Washington, D.C. 20530
Julie A. Edelstein
Senior Assistant Special Counsel
Special Bar ID #A5502949
2
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Case 9:23-cr-80101-AMC Document 371 Entered on FLSD Docket 03/07/2024 Page 3 of 4
David V. Harbach, II
Assistant Special Counsel
Special Bar ID #A5503068
3
PDF Page 5
Case 9:23-cr-80101-AMC Document 371 Entered on FLSD Docket 03/07/2024 Page 4 of 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on March 7, 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
4
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