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  • Trump Discovery Letter 10-23-2023 To Molly and J6 Team

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    Robert Gouveia
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    This letter requests discovery from prosecutors in the case United States v. Donald J. Trump, No. 23 Cr. 257 (TSC). It asks for documents relating to 59 specific requests, including any relating to complaints about the investigations of President Trump or President Biden, views disagreeing with investigations of election issues, decisions not to investigate election irregularities, acceptance of non-outcome determinative election fraud, and confirmation that witness files and materials have been reviewed. The letter is seeking this information in addition to general discovery obligations.

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    Trump Discovery Letter 10-23-2023 to Molly and J6 Team

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    This letter requests discovery from prosecutors in the case United States v. Donald J. Trump, No. 23 Cr. 257 (TSC). It asks for documents relating to 59 specific requests, including any relating to complaints about the investigations of President Trump or President Biden, views disagreeing with investigations of election issues, decisions not to investigate election irregularities, acceptance of non-outcome determinative election fraud, and confirmation that witness files and materials have been reviewed. The letter is seeking this information in addition to general discovery obligations.

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    © All Rights Reserved
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    139 views10 pages

    Trump Discovery Letter 10-23-2023 To Molly and J6 Team

    Uploaded by

    Robert Gouveia
    This letter requests discovery from prosecutors in the case United States v. Donald J. Trump, No. 23 Cr. 257 (TSC). It asks for documents relating to 59 specific requests, including any relating to complaints about the investigations of President Trump or President Biden, views disagreeing with investigations of election issues, decisions not to investigate election irregularities, acceptance of non-outcome determinative election fraud, and confirmation that witness files and materials have been reviewed. The letter is seeking this information in addition to general discovery obligations.

    Copyright:

    © All Rights Reserved
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    of 10

    Case 1:23-cr-00257-TSC Document 169-2 Filed 11/29/23 Page 1 of 10

    EXHIBIT B
    (Redacted)
    Case 1:23-cr-00257-TSC Document 169-2 Filed 11/29/23 Page 2 of 10
    LAURO & SINGER
    FLORIDA  NEW YORK
    FLORIDA
    400 N. Tampa Street
    15th Floor
    Tampa, Florida 33602
    P. 813.222.8990
    October 23, 2023
    F. 813.222.8991

    1101 Brickell Avenue Via Email: MGG@usdoj.gov; TPW@usdoj.gov


    South Tower, 8th Floor
    Miami, FL 33131
    P. 813.222.8990
    Molly Gaston
    Thomas P. Windom
    NEW YORK Senior Assistant Special Counsels
    250 E. 53rd Street 950 Pennsylvania Avenue NW
    Suite 1701 Room B-206
    New York, New York 10022
    P. 646.746.8659
    Washington, D.C. 20530

    Re: United States v. Donald J. Trump, No. 23 Cr. 257 (TSC)


    WWW . LAUROSINGER . COM
    Dear Ms. Gaston and Mr. Windom:

    We write on behalf of President Trump, to request that your office


    produce the following discovery pursuant to Rule 16(a)(1)(E), Brady v.
    Maryland, 373 U.S. 83 (1963), United States v. Agurs, 427 U.S. 97 (1976),
    Giglio v. United States, 405 U.S. 150 (1972) and their progeny; and the Fifth
    and Sixth Amendments to the United States Constitution. Simply pointing to
    the voluminous discovery produced as satisfaction of your constitutional
    obligations is not sufficient. In furtherance of your offer “to exceed [your]
    discovery obligations” and “provide substantial assistance to aid the
    Defendant’s review” (doc. 23 at 4), we request that you specifically search for
    and produce discovery responsive to the following discrete requests.

    I. Background

    Each of the Requests set forth below calls for production of documents
    irrespective of their classification level. As used herein, the term “documents”
    includes (i) all communications, including memoranda, reports, letters, notes,
    emails, text messages, and other electronic communications; (ii) hard copies
    and electronically stored information, whether written, printed, or typed; and
    (iii) all drafts and copies.

    As used herein, the term “foreign influence” is broader than the


    definition of the term “foreign interference” in Executive Order 13848 and
    includes any overt or covert effort by foreign governments and non-state
    actors, as well as agents and associates of foreign governments and non-state
    actors, intended to affect directly or indirectly a US person or policy or process
    of any federal, state, or local government actor or agency in the United States.
    Case 1:23-cr-00257-TSC Document 169-2 Filed 11/29/23 Page 3 of 10
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    Case 1:23-cr-00257-TSC Document 169-2 Filed 11/29/23 Page 5 of 10
    Page 4 of 9

    10. Please provide all documents relating to complaints or concerns by any prosecutor
    from DOJ, the Special Counsel’s Office, or any federal law enforcement agent relating to the
    conduct of the investigations of President Trump, the 2020 election, or President Biden.

    11. Please provide all documents related to views and opinions expressed by
    Department of Justice personnel, including from the Public Integrity Section and National Security
    Division, discouraging, disagreeing with, or resisting investigations of election fraud, interference
    (including foreign interference), anomalies, or irregularities related to the 2020 election.

    12. Please provide all documents related to or reflecting decisions by the Department
    of Justice, federal law enforcement, state law enforcement, election officials, or other government
    officials declining or refusing a review or investigation of election fraud, interference (including
    foreign interference), anomalies, or irregularities related to the 2020 election.

    13. Please provide all documents that the Special Counsel’s Office will rely upon at
    trial to argue that there was no fraud in the 2020 election.

    14. Please provide all documents indicating the acceptance of non-outcome


    determinative fraud within federal or state government elections.

    15. Please provide all documents defining “outcome determinative fraud.”

    16. Please provide all documents authored or reviewed by attorneys that support the
    legality of any action alleged in the Indictment.

    17. Please provide all audits of election results, vote tabulation, vote submission, or
    related election activities performed by State governments named in the Indictment.

    18. Please provide all statutes, rules, or policies regarding election audit procedures of
    the States named in the Indictment.

    19. Please provide all documents regarding any assessments of the opportunity or lack
    of opportunity for fraud or foreign interference in the 2020 election.

    20. Please provide all documents regarding State Legislature disagreement with any
    court decisions regarding the 2020 election.

    21. Please provide all documents regarding audits, checks, inspections, or reviews to
    ensure the integrity of mail-in ballots and their compliance with state laws and regulations.

    22. Please provide all documents regarding the compromise, diminishment, or


    lowering of the standards for mail-in ballots and their compliance with state laws and regulations
    related to the 2020 election.
    Case 1:23-cr-00257-TSC Document 169-2 Filed 11/29/23 Page 6 of 10
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    Case 1:23-cr-00257-TSC Document 169-2 Filed 11/29/23 Page 8 of 10
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    Case 1:23-cr-00257-TSC Document 169-2 Filed 11/29/23 Page 10 of 10
    Page 9 of 9

    58. Please confirm that you have conducted a case-file review consistent with Justice
    Manual § 9-5.002.

    59. Please confirm that your review of materials potentially subject to the Jencks Act
    and Giglio has included all electronic facilities used by each witness, including both classified and
    unclassified email accounts, classified and unclassified chat and messaging programs, personal
    email accounts, personal phones, and personal messaging apps.

    We expect to submit additional questions and requests on a rolling basis. Please let us
    know if you would like to discuss any of these issues.

    Respectfully Submitted,

    John F. Lauro
    Gregory M. Singer
    Filzah I. Pavalon
    LAURO & SINGER

    Todd Blanche
    Emil Bove
    Stephen Weiss
    BLANCHE LAW PLLC

    Attorneys for President Donald J. Trump

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