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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
United States of America,

Criminal No. 17-20775
v.
Honorable Robert H. Cleland
D-1 DINO BUCCI,
Defendant.

DISCOVERY NOTICE

1. The attorney for the government knows that the defendant made relevant
written or recorded statements, (including grand jury testimony), and/or
relevant oral statements made in response to interrogation, whether before or
after arrest, by a person then known to the defendant to be a government
agent, whether or not the statement is included in a written record, as
follows:
☒Not Applicable
Date

Agent/Agency

Type (written, recorded,
grand jury, oral)

2. The attorney for the government knows that defendant has a prior criminal
record:
☒NO

☐YES

3. The following books, papers, documents, photographs and tangible objects
are within the possession, custody or control of the government and are
intended to be used as evidence in chief at trial, are known to the
government to be material to the preparation of the defense, or were
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obtained from or belong to the defendant: e-mail, bank and financial records,
photographs, video recording of a bribe payment made to the defendant by
an individual cooperating with the government, audio recordings of
telephone calls with the defendant, hundreds of wiretap calls of the
defendant, including calls concerning extortion, bribery, and kickback
schemes, consensual recordings of meetings with the defendant, and other
business records.
4. Results or reports of the following physical or mental examinations, or
scientific tests or experiments, are within the possession, custody or control
of the government, and are either intended to be used as evidence in chief at
trial or are known to the government to be material to the preparation of the
defense: Not applicable.
5. The government intends to introduce at trial testimony from one or more
experts in the following areas of expertise: Not applicable.
6. The government may introduce evidence obtained from execution of the
following search warrants:
☒Not Applicable
Date(s)

Docket Number(s)

7. The government may introduce evidence obtained through wiretaps or other
electronic surveillance:
☐Not Applicable
Type: (wiretap, bug, etc.)

Docket Number(s)

Wiretap on the defendant’s
cell phone
Wiretap on the defendant’s
burner cell phone
Consensual Wiretap on
the cell phone of a
cooperating individual

14-US-60056-Rosen
14-US-60056-Rosen
14-US-60056-Rosen

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Wiretap on the cell
phone of another defendant

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14-US-60056-Rosen

8. The government intends to offer evidence under Rule 404(b), Fed. R. Evid.
☐Yes

☐No

☒Unsure

9. The government is aware of the obligations imposed by Brady v. Maryland,
373 U.S. 83 (1963), and its progeny and will comply with their obligation to
provide defense counsel with exculpatory evidence that is material to either
guilt or to punishment in time for effective use at trial.
10.If the government discovers additional information of the type described in
Paragraphs 1 through 8; it will advise defense counsel in writing.
Based on the specific request of the defendant’s counsel, the government
will make available for inspection or copying the items described in
Paragraphs 1, 3, and 4; will furnish the record referred to in Paragraph 2;
will provide a summary (which will include the witnesses= qualifications,
opinions, and the bases and reasons for the opinions) of the anticipated
testimony described in Paragraph 5 and will provide notice of the general
nature of the evidence referred to in Paragraph 8. The government=s
compliance with any specific request will trigger the defendant=s duty to
provide the reciprocal discovery denoted in Fed. R. Crim. P. 16(b)(1)(A)(C). If the defendant makes a general request for discovery the government
will construe it as a request for each item described in Fed. R. Crim. P.
16(a)(1) (A)-(G). The government=s compliance with the defendant=s

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general request will trigger the defendant=s duty to provide reciprocal
discovery of each item specified in Fed. R. Crim. P. 16(b)(1)(A)-(C).
Respectfully submitted,
DANIEL L. LEMISCH
Acting United States Attorney
s/David A. Gardey
DAVID A. GARDEY
s/R. Michael Bullotta

R. MICHAEL BULLOTTA
Assistant United States Attorneys
211 W. Fort Street, Suite 2001
Detroit, MI 48226
(313) 226-9591
Dated: December 1, 2017

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CERTIFICATE OF SERVICE
I hereby certify that on December 1, 2017, I electronically filed the
foregoing document with the Clerk of the Court using the ECF system which will
send notification of such filing to the following:
Stephen T. Rabaut
Attorney for Defendant

s/David A. Gardey

DAVID A. GARDEY
Assistant United States Attorney
Dated: December 1, 2017

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