Case 1:13-cr-01877-WJ Document 41 Filed 03/21/14 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO UNITED STATES OF AMERICA, Plaintiff, vs. JAMIE ESTRADA, Defendant. ) ) ) ) ) ) ) ) )

Criminal No. 13-1877 WJ

UNITED STATES RESPONSE TO MOTION TO COMPEL PRODUCTION OF EMAILS (Doc. 37) The United States hereby responds to the Motion of Jamie Estrada to Compel Production of Emails That Agent Michael Boady Has Testified That Governor Martinez and Her Staff Sent to Contacts Regarding Use of the Domains Susana2010.com and SusanaPAC.com (Doc. 37) and requests that the Court deny the Motion as moot. In support the United States offers the following: The United States has consistently gone above and beyond its discovery obligations in providing material to the defense in this case. The United States has no obligation to answer specific requests for production in criminal matters, and has no obligation to answer interrogatories with references to specific documents. In this instance, the United States refers Estrada to documents JM_0020, JM_0050-0053, FBI_00003-00007 and FBI_05973-05975. Included in this list are three additional pages of responsive material the United States received subsequent to the filing of Estradas Motion, which the United States has voluntarily produced to Estrada. The United States currently possesses no additional documents responsive to Estradas request, broadly construed.

Case 1:13-cr-01877-WJ Document 41 Filed 03/21/14 Page 2 of 2

Wherefore, the United States requests that the Motion of Jamie Estrada to Compel Production of Emails That Agent Michael Boady Has Testified That Governor Martinez and Her Staff Sent to Contacts Regarding Use of the Domains Susana2010.com and SusanaPAC.com (Doc. 37) be denied as moot.

Respectfully submitted: STEVEN C. YARBROUGH Acting United States Attorney

/s/ Filed Electronically FRED FEDERICI JEREMY PEA Assistant U.S. Attorneys P.O. Box 607 Albuquerque, New Mexico 87103 (505) 346-7274

I HEREBY CERTIFY that on March 21, 2014, I filed the foregoing electronically through the CM/ECF system, which caused the below counsel of record to be served by electronic means, as more fully reflected on the Notice of Electronic Filing. Zachary A. Ives Molly E. Schmidt-Nowara Attorneys for Jamie Estrada /s/ Filed Electronically Jeremy Pea, Assistant U.S. Attorney