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UNITED STATES MAGISTRATE COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-CR-80173-2-AMC 

UNITED STATES OF AMERICA )

) 

v. ) 

) 

WILLIAM MICHAEL SPEARMAN, ) 

Defendant. ) 

____________________________________) 

PERSUANT TO PROTECTIVE ORDER

GOVERNMENT’S THIRD RESPONSE TO 

THE STANDING DISCOVERY ORDER

The United States hereby files this third response to the Standing Discovery Order as to 

defendant, William Spearman. This response also complies with Local Rule 88.10 and Federal 

Rule of Criminal Procedure 16 and is filed pursuant to the Protective Order in this case. 

A. 5. Books, papers, documents, data, photographs, tangible objects, buildings or 

places, within the government’s possession, custody or control, which are 

material to the preparation of the defendant’s defense, or which the 

government intends to use as evidence at trial to prove its case in chief, or 

which were obtained from or belong to the defendant, may be inspected at 

a mutually convenient time at: the Office of the United States Attorney, 

500 A. Australian Ave., West Palm Beach, Florida, Suite 400. Please call 

the undersigned within 48 hours if you intent to review the evidence to set 

up a date and time that is convenient to both parties. 

The attachments to this discovery response are not necessarily copies of all 

the books, papers, documents, data, etc., that the government may intend to 

introduce at trial. 

Additionally, the government is in possession of a copy of the server that 

maintained “Website A” as is available for inspection at the Federal Bureau 

of Investigation – West Palm Beach. Communication with the undersigned 

in advance of previewing the same is advisable because of the technical 

nature of the evidence. 

B. DEMAND FOR RECIPROCAL DISCOVERY: Pursuant to the Standing 

Discovery Order, the United States requests the disclosure and production 

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

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

C. The government will disclose any information or material which may be 

favorable on the issues of guilt or punishment within the scope of Brady v. 

Maryland, 373 U.S. 83 (1963), and United States v. Agurs, 427 U.S. 97 

(1976). 

D. The government will disclose any payments, promises of immunity, 

leniency, preferential treatment, or other inducements made to prospective 

government witnesses, within the scope of Giglio v. United States, 405 U.S. 

150 (1972), or Napue v. Illinois, 360 U.S. 264 (1959). 

N. The government hereby repeats its previous request for stipulation by the 

defendant: 

1. The child pornography alleged by the government is in fact child 

pornography as defined within Title 18 United States Code Section 

2256(9) for purposes of proof of the elemental requirements of the 

indicted conduct; and 

2. Venue exists in the Southern District of Florida. 

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.

The attachments to this response include the following, having been provided this day via USAfX 

to the email address of counsel for the defendant: one (1) .PDF file entitled, “US v. Good, et al 

(Spearman), 22-CR-80173-2-AMC, RSDO3, Bates Numbers 02852-03732”. 

Respectfully submitted,

MARKENZY LAPOINTE

 UNITED STATES ATTORNEY

By: s/Gregory Schiller 

 Gregory Schiller 

Assistant United States Attorney

Florida Bar No. 

500 S. Australian Ave., Suite 400 

West Palm Beach, FL 33401

Tel: (561) 209-1045 

Email: gregory.schiller@usdoj.gov 

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By: s/Kyle Reynolds 

Kyle Reynolds 

Trial Attorney

U.S. Dept. of Justice, Criminal Division 

Child Exploitation and Obscenity Section 

Court ID # A5502872 

1301 New York Avenue, NW 

Washington, DC 20005 

Phone: (202) 616-2842 

Email: kyle.reynolds@usdoj.gov 

By: s/William Clayman

William G. Clayman

Trial Attorney

U.S. Dept. of Justice, Criminal Division 

Child Exploitation and Obscenity Section 

Court ID # A5502958 

1301 New York Avenue, NW 

Washington, DC 20005 

Phone: (202) 514-0040 

Email: william.clayman@usdoj.gov

 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 23, 2023, I electronically filed the foregoing document 

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

served this day on all counsel of record on the attached Service List in the manner specified. 

 s/Gregory Schiller 

 Gregory Schiller 

Assistant United States Attorney

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SERVICE LIST

United States v. William Michael Spearman

Case No. 22-CR-80173-2-AMC 

United States District Court 

Southern District of Florida 

Party Counsel

Plaintiff:

UNITED STATES OF AMERICA

Gregory Schiller

Assistant United States Attorney

500 S. Australian Ave., Suite 400 

West Palm Beach, FL 33401

Email: gregory.schiller@usdoj.gov 

via Notice of Electronic Filing generated by CM/ECF

Kyle Reynolds 

Trial Attorney

U.S. Dept. of Justice, Criminal Division 

Child Exploitation and Obscenity Section 

1301 New York Ave., NW 

Washington, DC 20530 

Email: kyle.reynolds@usdoj.gov 

via Notice of Electronic Filing generated by CM/ECF

William G. Clayman 

Trial Attorney

U.S. Dept. of Justice, Criminal Division 

Child Exploitation and Obscenity Section 

1301 New York Avenue, NW 

Washington, DC 20005 

Email: william.clayman@usdoj.gov

via Notice of Electronic Filing generated by CM/ECF

Defendant:

William Michael Spearman

Scott Berry

Assistant Federal Public Defender

250 South Australian Ave., Suite 400 

West Palm Beach, FL 33401

Email: Scott_Berry@fd.org 

via Notice of Electronic Filing generated by CM/ECF

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