Information Subject to Disclosure by the Government

(a) The Government’s Initial Disclosure Obligations. The Government shall disclose and make available for inspection the following within 7 days of Defendant’s arraignment, or promptly after acquiring possession: (1) Federal Rule of Criminal Procedure 16(a)(1) Information. If requested by a Defendant, the information described in Federal Rule of Criminal Procedure 16(a)(1). (2) Brady Material.

All information within the scope of Brady v. Maryland, 373 U.S. 83 (1963) and United States v. Agurs, 427 U.S. 97 (1976), and their progeny. (3) Defendant’s Identification. A description of the procedure and participants involved in any lineup, showup, photo spread, or similar procedure used in attempting to identify Defendant, and any pictures and photographs used. (4) Vehicles, Vessels, or Aircraft.

Any vehicle, vessel, or aircraft in the Government’s custody that was allegedly utilized in the commission of any offense charged. (5) Wire and Electronic Intercepts. All recordings and line sheets of intercepted communications relevant to the charged offense that were obtained in accordance with Title III of the Omnibus Crime Control and Safe Streets Act of 1968. (6) Grand Jury Transcripts.

Transcripts of the grand jury testimony of all witnesses who will testify in the Government’s case-in-chief, if subject to Federal Rule of Criminal Procedure 26.2 and to 18 U.S.C. § 3500. (b) The Government’s Later Pretrial Disclosure Obligations. No later than 14 days before trial, the Government shall disclose and make available for inspection the following: (1) Giglio Material. All information within the scope of Giglio v. United States, 405 U.S. 150 (1972), and its progeny.

(2) Prior Acts Evidence. A description of the general nature of any crime, wrong, or other act the Government intends to offer at trial under Federal Rule of Evidence 404(b) or other criminal activity the Government contends is intrinsic to the charged offense. 23 (c) Government’s Decision to Not Disclose. If the Government declines to disclose any information described in this Local Rule, it shall promptly file a notice specifying the information withheld and the grounds for withholding.

The notice may be filed ex parte and under seal. 24