Assignment of Judge

• Motion to Disclose Whether Court Was Assigned at Random

Bill of particulars

• Order granting as to unnamed and unindicted co-conspirators and other ambiguities in the indictment
• Bill of Particulars and Memorandum in Support concerning the charges and the aggravating circumstances
• Bill of Particulars re death notice
• Defense reply to Government opposition to Bill of Particulars re death notice
• United States v. Bass, Order requiring Bill of Particulars for all Aggravation Evidence.

Co-defendants

• Motion for discovery from co-defendants in joint trial

Demanding discovery under Rule 16 and Brady

• Letter to Government
• Motion for Discovery and Inspection
• Motion for Disclosure of Exculpatory Evidence
• Motion for Discovery and Inspection of Information and Evidence in Aggravation
• Motion for disclosure of USA's authorization recommendation to DOJ (to get at exculpatory evidence)

• Motions for discovery of exculpatory penalty phase evidence

Early production of Government witness list

• Defense letter concerning early production of Government witness list
• Motion for production of witness list

• Reply to Government opposition to production of witness list and venire list

Early production of Jencks and/or Brady materials

• Order granting in United States v. Gonzales (D.NM)
• Order granting in United States v. Rosado-Rosario (D.PR)
• Defense memorandum concerning early production of Jencks/Brady materials
• Defense letter concerning early production of Jencks/Brady materials

• Defense motion and memo concerning early production of Jencks/Brady materials

Informants, Cooperating Prosecution Witnesses, and Individuals interviewed but not to be called by the Government

• Motion for discovery concerning use of Informants and Cooperating Witnesses
• Motion for pretrial production of statements of individuals not to be called
• Motion to Disclose Contact between Government Agents and Potential Jailhouse Informants
  

Pre-DOJ-authorization discovery

• Order granting in United States v. Gonzales

Race discrimination

• Orders concerning discovery

• Order and Memorandum Opinion Denying Discovery in United States v. Holloway (MDTn)

Recent Relevant Cases

• U.S. v. Karake, District Court opinion re pretrial Brady/discovery

Rule 17 subpoenas

• FDPRC memo concerning Rule 17 subpoenas for jail/prison/medical records
• Motion concerning subpoena for Bureau of Prison information
• Motion concerning defense subpoena of medical and social history records of defendant and family members
• Order concerning defense subpoena of medical and social history records of defendant and family members
• Memoranda opposing Government subpoenas for defendant's social history records
• Memorandum responding to government motion to quash subpoena of FBI agents for suppression hearing
• Motion for subpoena of victim records and documents concerning impact on victim family

• Memorandum responding to Government (lack of standing to assert) opposition to defense subpoena for victim's employment records

Sanctions for Government's failure to to comply with ordered discovery

• Order treating case as non-capital from United States v. Rosado-Rosario (D.PR)

• Letter from Court to Government re depositions as sanctions for discovery violations

  • For further information, contact FDPRC .

Suppressible Evidence -- Government intention to use

• Motion for Notice (pursuant to Rule 12(d)(2)) of Government's intention to use specific evidence subject to suppression