Mr. Faraj,
This is the power point we made when we met with all defense counsel and defendants on October 20. I hope it is helpful in orienting you to the evidence and issues in this case. I’m also attaching the guidelines letter I sent to Tom Warshaw in April
this year.
We have turned over all discovery, most of it on CDs. Included are all pleadings submitted to obtain 2 wire taps, including the 10, 20 and 30-day reports, as well as the recorded calls themselves, the agents’ summaries, and the verbatim transcripts of
some of the most pertinent calls. We also turned over all search warrant documents, 302s, consensually recorded conversations, photographs, etc. etc. I believe there were 8 CDs. When you get the discovery from Tom Warshaw, if you feel something is missing,
let me know. I assume you can determine who the other defense attorneys are from ECF, but if not, I’ll provide that information to you – you may also want to check with them to see if you have what you need.
Thank you for contacting me today. I look forward to working with you.
Cindy Oberg