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SUGGESTED PRACTICES REGARDING DISCOVERY …

SUGGESTED PRACTICES REGARDING DISCOVERY IN complex CASESB ased on meetings with representatives from the Court, the United States Attorney s Office,and the CJA Committee for the Northern District of California, the following is a protocol of suggestedpractices REGARDING DISCOVERY in wiretap and other complex , document-intensive cases. This documentis not intended to expand the parties DISCOVERY obligations under Federal Rule of Criminal Procedure16, the Jencks Act, or other federal statutes or rules. Paragraphs 1 through 8 of the suggestedpractices correspond to paragraphs 1 through 8 of the Second Agreement REGARDING DISCOVERY inComplex Cases. Call Tapes: parties are encouraged to use digital media for audio files because digital files maybe easier to review and less expensive to reproduce for a multi-defendant , it is preferable that the naming conventions for the audio files, the monitoringlogs, and the transcripts be consistent so that it is easy to cross-reference the audio callswith the corresponding monitoring logs and transcripts.

SUGGESTED PRACTICES REGARDING DISCOVERY IN COMPLEX CASES Based on meetings with representatives from the Court, the United States Attorney’s Office,

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