From: ' To: ' Subject: RE: 2020.10.15 Notes re Call with Chiefs re Adams Disclosure Questions Date: Thu, 15 Oct 2020 23:51:41 +0000 This looks right to me. From: Sent: Thursday, October 15, 2020 5:35 PM To: Subject: 2020.10.15 Notes re Call with Chiefs re Adams Disclosure Questions Here are my notes of our call with the PC chiefs about some of the Adams disclosure issues I raised in an email. I've put the chiefs' responses to our questions in bold. Please supplement if you think I'm missing anything. 1) We seized two phones from Our plan is to produce the responsive materials in discovery, but wait to produce the full images of the phone until the 3500 deadline. Let us know if you think we should do something different. =thinks it is fine assuming we produce 3500 sufficiently far in advance of trial. We suggested 5 weeks in advance, which Ted says was fine. noted that we've been doing 8 weeks in advance for non-testifying 3500 and 4 weeks in advance for testifying 3500, so she thought this timing was appropriate. I noted that we're going to be marking conversations with Adams and about Adams and the incident on phone, so the defendant should already have the relevant materials. Chiefs said that sounded good. I said we're not going to be producing post-arrest recorded interview as Rule 16 but we will review it for Brady and produce it as 3500. Chiefs said that sounded good. 2) We obtained a search warrant relating to who is another woman that we believe Adams met at the MCC. The agents didn't execute the warrant. What is your view on whether we should produce it? On the one hand, the affidavit discusses Adams. On the other hand, producing it might undermine future investigative steps (like trying to renew and execute the warrant in the future). M aid he didn't think the unexecuted search warrant was Rule 16 or Brady, and that we should just include it as the agent's 3500. Bekah agreed and thought we should consider trying to do the warr