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| 15 Aug 2016 10:25 PM |
IN THE UNITED STATES FEDERAL COURT FOR THE DISTRICT OF LAS VEGAS.
United States of America, Plaintiff, v. Youtube910, Defendant. ____________________________________
EQUAL RIGHTS LAW FIRM'S REQUEST FOR DISCOVERY UNDER RULE 16.
Pursuant to Rule 16 of the Federal Rules of Criminal Procedure, the Equal Rights Law Firm hereby requests all of the following, if applicable, be produced and the United States is expected, and obligated, to comply:
1. Statements by the defendant generally. Any statement the United States, made by the Defendant, written or spoken, has possession of, that the United States intends on entering into the relevant proceedings (pursuant to Rule 16(a)(1)(A-B)). 2. Defendant's prior record. A full-and-complete transcript, as well as image-form of the defendant's prior record of arrests and/or convictions. The attorneys-at-bar certify that the noted records are imperative to the providence of a complete defense for our client (pursuant to Rule 16(a)(1)(D)). 3. Documents generally. All documents, data, photographs, etc. which are in the custody or possession of the government and: A. the government intends to present to the court in its case-and-chief; or B. are property of the defendant (pursuant to Rule 16(a)(1)(E)). 4. Recordings generally. Timestamps of each alleged criminal act or crime, each timestamp accompanied by the statute which details the crime, as well as the citation for such; the video(s) in question; and annotations specifying how any other evidence or documentation produced under this discovery may be used to further points relating to video. 5. Witness testimonies. Complete transcript outlining what each witness is intended to testify during trial, annotations detailing how such testimony relates to the case, as well as a full and complete document of all questions to be posed to such witnesses, by order of name.
This request is made on the grounds that the information requested is necessary for a suitable defense to be provided, and that the sheer bulk of evidence makes it difficult for the Equal Rights Law Firm to search for the incidences of alleged crimes (especially when the Firm is inclined to believe that no such crimes have taken place).
Dated 8/15/2016. Equal Rights Law Firm.
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