Free Response to Motion - District Court of Arizona - Arizona

i U.S. Department of Justice
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District ot Artitona
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February 10, 2006
Patricia Gitre
331 N. First Ave., Suite 150
Phoenix, AZ 515003
Re: Unite:} 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 substance ot`which is new being provided to you. The purpose of the letter is to communicate
certaitt information to yotu client that may, or may not, play a role in his decision to enter a plea agreement.
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, 20015. However, the
ease agent for this case, Joe Slatalla of the ATF, claims that the government ltnew or could have known of
the material prior to that date. It is the govcrnrnent`s desire that you know of the dispute prior to enteritig
a change of plea, and that is why you have been provided with this letter. You should also he aware that the
potential discovery, even if relevant and discoverable, is included in the goverinncnt"s request tor a
protective order tiled on J anuary 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 weelts. 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 work can be alleviated. I look forward to your response.
lf you have any questions or require any further information, please call me at 514-2500.
Sincerely yours,
PAUL K. CHARLTON
United States Attorney
District of Arizona
ruvtornv
Assistant Llnitcd States Attorney
Case 2:03-cr-01167-DGC Document 1281 -4 Filed O2/27/2006 Page 1 of 1

Case 2:03-cr-01167-DGC

Document 1281-4

Filed 02/27/2006

Page 1 of 1