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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 20-61386-CIV-UNGARO

Magistrate Judge McAliley

CARLINE MAURICE

v.

UNITED STATES OF AMERICA

 /

GOVERNMENT'S SUPPLEMENTAL RESPONSE TO DECEMBER 15, 2020 ORDER

The United States of America respectfully responds as follows 

to this Court’s Order, DE 15, for a supplemental response:

1. That order directed the United States to:

[discuss] the nature surrounding its June 2, 2016 letter 

to Atty Gibson, and provide copies of any communications, 

letters, and e-mails from Atty Gibson responding to the 

June 2, 2016 letter.

DE 15:2. The June 2, 2016 letter addressed the terms of a proffer 

session with movant and her attorney, Mr. Gibson; the prosecutor, 

and special agents from the Internal Revenue Service (IRS). The 

session was arranged at the request of defense counsel which was

likely made orally; there are no letters or electronic mail messages 

requesting such a meeting. The proffer letter was provided to Mr. 

Gibson in person when he and movant arrived for the proffer session. 

Mr. Gibson and movant were provided with an opportunity to privately 

review the June 2 letter. The letter was then signed by movant, her 

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attorney, and the prosecutor, who provided an executed copy of the 

proffer letter to Mr. Gibson in a later electronic mail message dated 

June 29, 2016. A copy of the transmittal message is attached. There 

are no letters, e-mails or records of other communications from 

Attorney Gibson in response to the June 2 letter; any such responses 

were provided orally during the meeting, or in one instance, through 

a correction to Mr. Gibson’s address written on the letter itself. 

The proffer session was not productive and did not result in any offer 

of a plea bargain.

2. The order also directed the United States to “attach any 

and all e-mails from Atty Gibson responding to the Government’s email 

of July 7, 2016, and any Government responses thereto.” DE 15:2. 

The United States did not receive any response to the July 7 message 

from Mr. Gibson by electronic mail.

3. Finally, this Court’s order directed the United States to:

provide a copy of any recorded phone conversations which 

Movant claims to have occurred on or about August 29, 2019 

between Movant and Atty Gibson from the facility where 

Movant was confined at the time. If no such recording 

exists, the Government shall so indicate in its response, 

providing objective evidence, in the form of redacted 

prison phone logs establishing whether or not Movant made 

or received any phone calls from Atty Gibson on or about 

the date alleged.

DE 15:2. On December 15, 2020, the prosecution initiated a request 

for records by contacting the Bureau of Prisons’ Miami Consolidated 

Legal Center. An electronic message on December 15, 2020 confirming 

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receipt of the request advised that the BOP does not record properly 

placed legal calls, and that calls placed on an inmate line would 

be purged within six months, absent timely legal process. A 

subsequent electronic mail message from movant’s designated BOP 

facility also included the statement that [recordings of] phone calls 

are purged after six months.

4. The BOP has produced a four-page log listing calls for the 

phone number associated with Attorney Gibson. The log includes 

entries for numerous inmates other than movant. Accordingly, and 

at the request of the BOP, the United States is attaching a redacted 

version of the log showing calls involving movant and Mr. Gibson 

during the relevant time period of August, 2019. There are only two 

such calls, dated August 6 and August 20, 2019; thus, the redacted 

log has content on only two pages. If needed, the United States can 

produce an unredacted version of the log to the Court.

Respectfully submitted,

ARIANA FAJARDO ORSHAN

UNITED STATES ATTORNEY

By: s/Karen E. Rochlin 

KAREN E. ROCHLIN

ASSISTANT U.S. ATTORNEY

99 N.E. 4th Street

Miami, Florida 33132

(305) 961-9234

Court I.D. No. A5500050

karen.rochlin@usdoj.gov

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CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing 

was served by CM/ECF and by mail on Carline Maurice, No. 12700-104, 

Coleman Federal Correctional Complex-Camp, P.O. Box 1027, Coleman, 

Florida 33521-1027.

s/ 

KAREN E. ROCHLIN

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