Governments Initial Pretrial Conference Summary Statement

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGANSOUTHERN DIVISIONUNITED STATES OF AMERICAPlaintiff,v. Case No.Defendant(s). Hon.GOVERNMENT'S INITIAL PRETRIAL CONFERENCE SUMMARY STATEMENT I. DISCOVERY A. Statements of Defendant There are no written records of oral statements or other oral statements asdefined in Rule 16(a)(1)(A).1.Oral Statements (Rule 16(a)(1)(A)) There are the following written records of oral statements: The substance of which has been disclosed to defense counsel. will be disclosed to defense counsel by . There are no written or recorded statements or grand jury testimony ofdefendant.2.Written or Recorded Statements (Rule 16(a)(1)(B)) All written or recorded statements have been disclosed to defense counsel. will be disclosed to defense counsel by . There are the following written or recorded statements or grand jurytestimony: American LegalNet, Inc. www.FormsWorkFlow.com The Government has made due inquiry and is not aware of any prior criminal record.B. Defendant's Prior Record (Rule 16(a)(1)(D)) The Government has disclosed defendant's prior criminal history. The Government is now making inquiry into defendant's prior criminal history. The results will be disclosed to defense counsel upon receipt.C. Documents and Tangible Objects (Rule 16(a)(1)(E)) The Government has no documents, tangible objects, or physical evidence required to be disclosed. The Government has the following documents, tangible objects, and physical evidence: Controlled Substances: Records: Firearms: Other: The Government voluntarily notifies the defendant of the following search warrants issued and the warrant returns: State Federal: Case No. Re: Re: Case No. Re: Case No. They have been made available for inspection and copying by defense counsel. Defense counsel should make arrangements with: Drug Paraphernalia Drug Records Inventory (attached)D. Reports of Examinations and Tests (Rule 16(a)(1)(F)) The Government has no reports of examinations or tests required to be disclosed by Rule 16. The Government has or expects to have reports of the following examinations and tests: Drug Analysis Handwriting Fingerprints Gun Operability Firearms/Nexus DNA Other: Computer Forensics The Government seeks reciprocal discovery.E. Reciprocal Discovery American LegalNet, Inc. www.FormsWorkFlow.com F. Notice Under FRE 404(b) The Government does not presently intend to introduce 404(b) evidence. The Government does presently intend to introduce the following 404(b) evidence: The Government will provide pretrial notice of 404(b) evidence by .G. Other Discovery Matters non-jury trial. juryA.The Government requests aII.TRIAL B.The length of trial excluding jury selection is estimated at. The Government is aware of the following potential conflicts: The Government is unaware at this time of any known conflict with defendant's representation by counsel. The United States will immediately advise counsel if any such conflict becomes known.III.MISCELLANEOUS Government's plea negotiation policy:The parties acknowledge that if the case is appropriate for expedited resolution, a jointmotion for expedited sentencing shall be filed within 14 days of arraignment. Counsel for the United States Date(Rev. 03/01/2019) American LegalNet, Inc. www.FormsWorkFlow.com