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UNITED STATES DISTRICT COURT
for the Middle District of Oceana
Criminal Division--Felony Branch
UNITED STATES OF AMERICA
ANGELA SMITH
GOVERNMENT’S REPLY TO DEFENDANT’S MOTION FOR DISCOVERY AND INSPECTION
Pursuant to Fed. R. Crim. P. 16, the United States, by and through Assistant United States Attorney Rhonda Johnson, hereby responds to the defendant’s discovery motion by filing this reply.
1. Defendant’s motion seeks discovery and inspection of the marked money used by Detective Brown during an undercover narcotics transaction with defendant. The government had previously provided defendant with all materials that are discoverable pursuant to Fed. R. Crim. P. 16. As defendant states in his motion, defense counsel has already visited the DEA laboratory and inspected the narcotics involved in the transaction leading to the instant charges.
2. Under Rule 16, tangible objects discoverable by the defendant must be relevant and material to the case. The United States will not use the
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