Court Records

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UNITED STATES OF AMERICA, plaintiff	:
VS.	:	CASE No. 75-26-CR-3
JEFFREY R. MACDONALD, defendant	:

To The Honorable George Anderson, United States Attorney For The Said District:

The Defendant, Jeffrey R. MacDonald, by his attorneys, requests the United States Attorney to make appropriate preparations now to have available for prompt production to the Defendant the following Jencks Act and/or Brady materials which have not heretofore been provide to him. The request is made as of this date to assure that there will be no delay in the commencement of the defense case as would be necessitated by the unavailability of the said materials. The Defendant's request includes, but is not limited to the following:

(1) Transcript of testimony of all persons who appeared before the grand jury in this case, but who have not been called by the Government and whose testimony was not previously supplied by the Defendant.

(2) All statements and reports of and by each and every person listed by the government on the list of witnesses submitted by it to the Defendant at the beginning of the trial.

(3) All recording tapes and transcripts of taped conversations between the Defendant and Alfred and/or Mildred Kassab which are in the possession of the Government, or have been in its possession, or are available to it upon its request.

(4) All letters sent by the Defendant to Alfred and/or Mildred Kassab which are in the possession if the Government, or have been in its possession, or are available to it upon its request.

(5) Copies of all letters sent by Alfred Kassab and/or Mildred Kassab to the Defendant which are in possession of the Government, or have in its possession, or are available to it upon its request.

(6) Correct addresses for the following persons whose names were supplied to the Defendant by the Government on July 13, 1979. Investigation by the Defendant reveals that these persons cannot be contacted at the addresses supplied and the Defendant has otherwise been unable to ascertain the whereabouts of those persons:

Kenneth Beasley
Darrell Jack Bennett
John Caldwell
Carolyn Goldman
Tom Hagney
James A. King
Robert D. Olsen
Julian J. Ossman
James W. Paulsen
Myron Pickering
Willard A. Spessert
Helena Stoeckley