Free Motion for Miscellaneous Relief - District Court of Arizona - Arizona

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February 10, 2006
Pauicia Gitre
331 N. First Ave., Suite 150
Phoenix, AZ 515003
Re: United Stores v. Johnston et ot.
Deut Counsel:
Some of your nurnher, those that have been more actively participating in plea negotiations. received
a letter, the substanee ofwhich is new being provided to you. The purpose of the letter is to communicate
eertaitt information to yotn· client that may, or may not, play a role in his decision to enter a plea agreentent.
As you lcnow, on January ti, 200ti, the government tiled a Notice of Potential Discovery. The potential
discovery referenced in that notice was not ltnown hy the government until January 3, 200o. However, the
case agent for this case, Joe Slatalla ofthe ATF, claims that the government lttiew or could have known of
the niaterial prior to that date. It is the governtnent`s desire that you know of the dispute prior to entering
a change of plea, and that is why you have been provided with this letter. You should also be aware that the
potential discovery, even if relevant and diseoverable, is included in the goverinnent"s request tor a
protective order tiled on January 13, 2006, and would have been the subject of a request tbr a protective
order even if it had been discovered at an earlier date.
Please respond with your client’s wishes regarding a plea agreement as soon as possible. As you are
aware. over the coming weelcs. there is a great deal ot`worl·r scheduled to be done on both our parts. lf your
client wants to enter a change of plea, some of that worlt can be alleviated. I look forward to your response.
lf you have any questions or require any further information, please eall me at 514-2500.
Sincerely yours,
PAUL K. CHARLTON
United States Attorney
District of Arizona
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Assistant Llnited States Attorney
Case 2:03-cr-01167-DGC Document 1218-2 Filed O2/14/2006 Page 1 of 1

Case 2:03-cr-01167-DGC

Document 1218-2

Filed 02/14/2006

Page 1 of 1