See United States v.Tarantino
, 846 F.2d 1384, 1414 n.11 (D.C. Cir. 1988);
Advisory Committee Note to Fed.R. Crim. P. 16 (1974) (“The rule is intended to prescribe the minimum amount of discovery to which the parties are entitled.”). Where doubt exists as to the usefulness of the evidence to the defendant, the government must resolve all such doubts in favor of full disclosure.
See United States v. Paxson 861 F.2d 730, 737 (D.C. Cir. 1988). Accordingly, the Court, sua sponte, directs the government to produce to defendant in a timely manner – including during plea negotiations– any evidence in its possession that is
See United States v. Ohiri , 133 F. App’x 555, 562 (10th Cir. 2005);
United States v. Avellino , 136 F.3d 249, 255 (2d Cir. 1998);
Sanchez v. United States , 50 F.3d 1448, 1453 (9th Cir. 1995);
White v. United States , 858 F.2d416, 422 (8th Cir. 1988);
Campbell v. Marshall , 769 F.2d 314, 322-24 (6th Cir.1985);
United States v. Nelson, 979 F. Supp. 2d 123, 135-136 (D.D.C. 2013
); Buffey v. Ballard , 782 S.E. 2d 204 (W. Va. 2015).
favorable to defendant and material either to defendant’s guilt or punishment. The government is further directed to produce all discoverable evidence in a readily usable form. For example, the government must produce documents as they are kept in the usual course of business or must organize and label them clearly. The government must also produce electronically stored information in a form in which it is ordinarily maintained unless the form is not readily usable, in which case the government is directed to produce it in a readily usable form. If the information already exists or was memorialized in a tangible format, such as a document or recording, the information shall be produced in that format. If the information does not exist in such a format and, as a result, the government is providing the information in a summary format, the summary must include sufficient detail and specificity to enable the defense to assess its relevance and potential usefulness.
Finally, if the government has identified any information which is favorable to the defendant but which the government believes not to be material, the government shall submit such information to the Court for