1

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-20340-CR-WILLIAMS(s)

UNITED STATES OF AMERICA

v. 

MASPHAL KRY, 

 Defendant. 

____________________________________/

GOVERNMENT=S FOURTH RESPONSE TO

THE STANDING DISCOVERY ORDER

The United States hereby files this supplemental response to the Standing Discovery Order. 

An electronic storage device containing the materials listed on the attached discovery log 

is being supplied with the service copy of this Response. 

The majority of the materials being provided are in the nature of early Jenks. The authors 

of the various Reports of Investigation are identified in each document. Unless otherwise 

specified, and consistent with the position taken by the United States regarding such materials 

during various status conferences, the United States is making these materials available in 

anticipation of the authors being witnesses at trial of this matter. Because of the volume, early 

Jenksis appropriate and consistent with the wishes expressed by the Court. There will be additional 

productions of Jenks statements in the future but minimal in comparison with the present 

production. 

 In addition to its character as Jenks, some of the Reports reference issues that appear to be 

within the scope of the defense(s) being raised to the pending charges as the government perceives 

them. To the extent that the government has recognized those relationships, the following Reports 

of Investigation [identified by the three numerals following the letter “R” on the report] would 

appear to fall within the defense view of Brady material and be a possible source of exculpatory 

evidence, or for use in crafting cross-examination of government witnesses: 

 009 016 022 023 024 025 027 029 036 041 046 047 

 048 074 075* 076 099 103 106 113 116 119 148 223 

 237 242 254 277 299 313 314 318 330 336 338 355 

• This report may also include material regarded as within the scope of Giglio with respect 

to the government’s cooperating private individual.

Case 1:22-cr-20340-KMW Document 148 Entered on FLSD Docket 07/11/2023 Page 1 of 3
2

. To date, the United States has received no reciprocal discovery in this matter. Accordingly, 

pursuant to the Standing Discovery Order, the United States renews its request for the disclosure 

and production of materials listed in Section (b) of Local Rule 88.10. This request is also made 

pursuant to Rule 16(b) of the Federal Rules of Criminal Procedure.

The government is aware of its continuing duty to disclose such newly discovered 

additional information required by the Standing Discovery Order, Rule 16(c) of the Federal Rules 

of Criminal Procedure, Brady, Giglio, Napue, and the obligation to assure a fair trial.

Attachment 1 hereto is a log reflecting the discovery materials being provided on the 

electronic media accompanying the service copy of this Response. Please contact the undersigned 

Assistant United States Attorney if any items are missing or not accessible.

Respectfully submitted,

 MARKENZY LAPOINTE

 UNITED STATES ATTORNEY

.By: /s/ Thomas A. Watts-FitzGerald 

Assistant United States Attorney 

Florida Bar No. 0273538 

99 Northeast 4th Street 

Miami, Florida 33132-2111 

Tel: (305) 961-9413 

By: /s/ Emily R. Stone 

Assistant United States Attorney

Florida Bar No. 92077 

99 Northeast 4th Street 

Miami, Florida 33132-2111 

Tel. 305-961-9407 

cc: Special Agent D. Manera 

USFWS OLE 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on July 11, 2023, I electronically filed the foregoing document 

with the Clerk of the Court using CM/ECF. I also certify that the foregoing document with the 

Case 1:22-cr-20340-KMW Document 148 Entered on FLSD Docket 07/11/2023 Page 2 of 3
3

described electronic media is being served by hand-delivery this day on John Byrne, Esq., counsel 

for defendant Masphal Kry. 

/s/ Emily R. Stone 

Assistant United States Attorney

Case 1:22-cr-20340-KMW Document 148 Entered on FLSD Docket 07/11/2023 Page 3 of 3