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Case 0:12-cr-60298-RNS Document 107 Entered on FLSD Docket 06/12/2013 Page 1 of 2

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO. 12-60298-CR-SCOLA/O’SULLIVAN

UNITED STATES OF AMERICA

v.

RAEES ALAM QAZI,
a/k/a “Shan,” and
SHEHERYAR ALAM QAZI,

Defendants.

____________________________

GOVERNMENT’S SUPPLEMENTAL RESPONSE TO

THE STANDING DISCOVERY ORDER

The United States hereby files this third supplemental response to the Standing Discovery
Order. This response also complies with Local Rule 88.10 and Federal Rule of Criminal Procedure
16, and is numbered to correspond with Local Rule 88.10.

1.



A.

B.

Copies of audio recordings were provided to defense counsel on June 5, 2013
(9 DVDs).

Additionally, on June 5, 2013, counsel were advised that upon the providing
of a 1 TB hard drive, they would receive a mirror imagine of various
electronic items seized in this case, including, a laptop computer, a MP3
player, two external hard drives, a GPS, and cellular telephones.

DEMAND FOR RECIPROCAL DISCOVERY: The United States requests
the disclosure and production of materials enumerated as items 1, 2 and 3 of
Section B of the Standing Discovery Order. This request is also made
pursuant to Rule 16(b) of the Federal Rules of Criminal Procedure.

The government is aware of its continuing duty to disclose such newly discovered additional
information required by the Standing Discovery Order, Rule 16(c) of the Federal Rules of Criminal

Case 0:12-cr-60298-RNS Document 107 Entered on FLSD Docket 06/12/2013 Page 2 of 2

Procedure, Brady, Giglio, Napue, and the obligation to assure a fair trial.

Respectfully submitted,





WIFREDO A. FERRER
UNITED STATES ATTORNEY

By:

/s/ Karen E. Gilbert

Karen E. Gilbert

Assistant United States Attorney
Florida Bar No. 771007
99 Northeast 4th Street
Miami, Florida 33132-2111
Tel: (305) 961- 9161
Fax: (305) 536- 4675
[email protected]

cc:

Special Agent Paul Carpinteri
FBI

CERTIFICATE OF SERVICE

I HEREBY CERTIFY hereby certify that on June 12, 2013, I electronically filed the

foregoing with the Clerk of the Court by using the CM/ECF system.

/s/ Karen E. Gilbert
Assistant United States Attorney

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