Free Notice (Other) - District Court of Delaware - Delaware

Case 1 :05-cr-00036-JJF Document 20 Filed 05/04/2005 Page 1 of 4
L1guor1, Morr1s & Yl€l1gSt
\~( Attorneys At Law
> 46 The Green, Dover, Delaware 19901
Q (302) 678-9900 · Fax (302) 678-3008
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James E. Liguori
Gregory A. Morris
Laura A. Yiengst
May 2, 2005
April Byrd, AUSA
1007 Orange Street, Suite 700
Wilmington, DE 19801
RE: United States v. Gwennette Bowman
Criminal Action N0. 05-36(JJF)
Dear April:
l represent the defendant in the above-referenced matter. Pursuant to
Federal Rule of Criminal Procedure 16, Brady v. l\/laryland, 373 U.S. 83 (1963)
and Giglio v. United Stag, 405 U.S. 150(1972), l request that you provide me
with the following by way of discovery:
(1) The date, time and location of each and every alleged offense,
including relevant conduct.
(2) Copies of any and all written statements, confessions, or
admissions of the defendant, including transcripts of recorded
statements, indicating the date, time and locations where the
statement was made and the names of the law enforcement agents
and/or officers who were present.
(3) The substance of any oral statements made by the defendant,
including access to the original tape of any audio or video tape
recorded statement as well as photocopies of any handwritten
notes taken by any law enforcement agent and/or officer present
during the defendant’s giving of the oral statement, indicating the
date, time and location of the oral statement and the agent’s and/or
officers present, as well as, that portion of any written record
including any written reference which would provide some means
for the prosecution and defense to identify the statements,
containing the substance of any relevant oral statement by the
defendant.
a. Those portions of any pretrial statements and/or Grand Jury
testimony of prospective Government witnesses which contain

Case 1:05-cr-00036-JJF Document 20 Filed 05/04/2005 Page 2 of 4
statements attributable to the defendant, either declarations of
the defendant or various declarations imputed to the defendant
under the Federal Rules of Evidence, e.g., statements of co-
conspirators.
(4) information with respect to the prior federal and/or state arrest and
conviction record of the defendant, including specifically any prior
convictions that would trigger enhanced or mandatory penalties or
potential habitual offender status in the event of conviction on the
pending charge.
(5) information on any other criminal charges or investigations now
pending with respect to the defendant.
(6) Reports of physical or mental examinations of the defendant by a
physician, dentist, psychiatrist or psychologist in regards to the
defendant.
(7) information with respect to the prior federal and/or state arrest and
conviction record of the co-defendant and co—conspirators;
statements by co—defendants.
(8) information regarding any identification procedures, any
identifications made of the defendant, any misidentification or
failure to identify by any government witnesses.
(9) Reports of any and all forensic or scientific tests with respect to this
case or related investigation conducted by the police, medical
examiner, FBI, DEA, SBI, prosecution or experts retained for those
purposes.
a. A written summary of any expert testimony intended for use at
trial pursuant to Federal Rules of Evidence 702, 703 or 705,
which will include, but will not be limited to, the witness’(es’)
opinions, basis and reasons and qualifications.
(10) A listing of and the opportunity to inspect all books, papers,
documents, and any other physical evidence which were seized
from the defendant or which the Government intends to use against
the defendant at trial.
(11) An opportunity to review all photographs, videotapes, audiotapes
(including but not limited to any 911 calls), any magnetic record
tapes, maps, diagrams, and charts in the possession of the
government relating to this matter.
(12) Copies of all applications for, returns from and affidavits in support
of all search warrants (whether executed or inexactitude in this
matter).
(13) Copies of all arrest warrants in this matter, including supporting
affidavits, and disclosures of the date, time, place, and arresting
officer(s) with respect to any warrantless arrest.
(14) Disclosure of any and all uses of a pen register (a dialed number
recorder) and of interception of telephone communications and
transcripts of communications.

Case 1:05-cr-00036-JJF Document 20 Filed 05/04/2005 Page 3 of 4
(15) Disclosure of the nature of any evidence, pursuant to Federal Rule
of evidence 404(b) which the Government intends to introduce at
trial.
(16) Disclosure of any criminal record/juvenile adjudication of
prosecution witnesses in any jurisdiction, especially Robert "Bob"
Singer.
(17) Disclosure of the identity of any and all informants who participated
in the investigation of this matter.
a. Any drug or alcohol use by witnesses and/or informants;
b. Any drug/alcohol use by witnesses and/or informants at the time
of the incident(s) charged and thereafter;
c. Any information that any prosecution witness suffers from
mental illness.
(18) Disclosure of any and all agreements (benefits, promises or
statement that a benefit would not be provided without cooperation)
in any form, between any agent of the Government and any
witnesses, accessory, principal or accomplice (whether charged or
not) including whether such individual has been or will be promised
transactional or use immunity from prosecution or any other
consideration in return for testimony, especially Robert "Bob"
Singer.
(19) Disclosure of statements, interviews, reports or other information
relating to the credibility of any prosecution witness, including but
not limited to, inconsistent statements, reports, priortestimony,
evidence of bad character and specific acts of dishonesty 1
admissible, not only for conventional impeachment, but also under
Federal Rule of evidence 806.
a. All handwritten notes of Government agents with respect to
interviews conducted in this investigation including, but not
limited to the handwritten notes prepared by agents who
interviewed the defendant as requested in paragraph (2) of this
discovery request.
(20) An opportunity, pursuant to Jencks v. U.S., 353 U.S. 657 (1957), to
review reports and statements, whether written or recorded, made
by persons who will testify at trial, regardless of whether the
individual will use the statement or report to prepare the
examination. l would appreciate it if you would share this
information with me prior to trial in order to avoid delay prior to
cross-examination.
(21) Disclosures of any and all exculpatoiy information, evidence or
witnesses known to the Government or any Government agent,
including any such information which is favorable or significant to
the defense or which might create a reasonable doubt as to guilt.
See Brady v. Maryland, 373 U.S. 83 (1963).

Case 1:05-cr-00036-JJF Document 20 Filed 05/O4/2005 Page 4 of 4
l would appreciate your prompt response to the foregoing requests so that
we may proceed to trial without delay.
Thank you for your cooperation.
Very truly yours,
QE/ff
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