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MICHAEL BAILEY 

United States Attorney 

ANNA WRIGHT

Assistant U.S. Attorney 

NATHANIEL J. WALTERS 

Assistant U.S. Attorney 

State Bar No.: 029708 

405 West Congress, Suite 4800 

Tucson, Arizona 85701-5040 

Telephone: (520) 620-7300 

E-mail: anna.wright@usdoj.gov 

 nathaniel.walters@usdoj.gov 

Attorneys for Plaintiff 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

United States of America, 

 Plaintiff, 

 vs. 

Scott Daniel Warren, 

 Defendant.

18-CR-223-TUC-RCC (DTF) 

GOVERNMENT’S REQUEST FOR 

NOTICE OF DEFENSES 

The United States of America, by and through its undersigned attorneys, pursuant 

to Federal Rules of Criminal Procedure 12, 12.1, 12.2, and 12.3, hereby requests timely 

and accurate notice of the defendant’s intent to assert the defense of entrapment, duress, 

coercion, alibi, insanity or any other mental condition, and public authority. 

1. Pursuant to Rule 12(e), the United States requests from the defendant that he 

provide notice of intention (if any) to use the defenses of entrapment, duress, or coercion. 

2. Pursuant to Rule 12.1, the United States requests from the defendant that he 

provide notice of intention (if any) to offer the defense of alibi. The United States 

specifically requests the name(s) of the location(s) and the hour(s) where the defendant 

claims to have been at the time(s) specified in the Indictment. The United States also 

requests the name(s) and address(es) of the witness(es) upon whom the defendant intends 

to rely to establish an alibi defense. 
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3. Pursuant to Rule 12.2, the United States requests from the defendant that he 

provide notice of intention (if any) to use an insanity defense or to present expert testimony 

relating to a mental disease or defect or any other mental condition. 

4. Pursuant to Rule 12.3, the United States requests from the defendant that he 

provide notice of intention (if any) to use the defense of actual or believed exercise of 

public authority on behalf of a law enforcement or federal intelligence agency. 

Failure to comply with the notice requirements as specified in the above referenced 

sections of the Federal Rules of Criminal Procedure will result in the government moving 

to preclude such defenses in the event that they are brought untimely or if the notice 

regarding one of the above defenses is predicated on insufficient information. 

WHEREFORE, it is respectfully requested that this Court take notice of the 

aforementioned, and for such other and further relief that is just and proper. 

Respectfully submitted this 30th day of September, 2019. 

 MICHAEL BAILEY 

United States Attorney 

District of Arizona 

 /s/ Anna R. Wright & Nathaniel J. Walters

 ANNA WRIGHT &

 NATHANIEL J. WALTERS 

 Assistant U.S. Attorneys 

Copy of the foregoing served electronically or by 

other means this 30th day of September, 2019, to: 

All ECF participants