United States v. Franco

585 F. Supp. 2d 980, 2008 U.S. Dist. LEXIS 93604, 2008 WL 4906001
CourtDistrict Court, N.D. Ohio
DecidedNovember 17, 2008
Docket3:08CV304
StatusPublished

This text of 585 F. Supp. 2d 980 (United States v. Franco) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Franco, 585 F. Supp. 2d 980, 2008 U.S. Dist. LEXIS 93604, 2008 WL 4906001 (N.D. Ohio 2008).

Opinion

ORDER

JAMES G. CARR, Chief Judge.

This is a criminal case in which the defendant Franco has filed a motion to unseal transcripts of any oral testimony taken under oath when the undersigned issued orders authorizing electronic surveillance pursuant to 18 U.S.C. § 2510 et seq., oral statements made during periodic reports during the execution of the orders and copies of any written reports. [Doc. 125],

The government does not oppose the request for transcripts. The government asks, though, that it review the transcripts to redact information relating to other investigations, or other information it desires not to disclose, before dissemination to the defendants. The government then proposes providing the original and redacted versions to me for further review to determine the propriety of redaction. 1

The government shall prepare, review and submit the transcripts to me as it proposes. To the extent that the time required for it to do so necessitates an adjustment of the pretrial motion schedule with regard to motions to suppress the *981 surveillance evidence, I will make whatever adjustment is needed once defense counsel have received the transcripts.

With regard to the defendant’s request for copies of any written progress reports: there are, as the government notes, no formal written reports. The only written materials submitted during progress reports are the monitors’ call logs. The logs note the duration of the call, whether the call was pertinent and the apparent subject of the call. Monitors also summarize the content of pertinent calls.

I review the logs in the interim between their submission and the next progress report date. I then notify the government if I have any concerns with regard to its compliance with the minimization directive.

The government argues that there is neither statutory nor other basis for ordering production of the call logs. I agree that neither Title III nor the Rules of Criminal Procedure specifically authorizes the discovery sought by the defendant’s motion. But that does not mean that I cannot order such production, or that it should not occur.

Section 2518(8)(d) of Title III requires service of a post-surveillance “inventory” within ninety days after termination of the surveillance. The inventory goes to persons named in the order and others as directed by the judge, and informs them of: 1) entry of the order; 2) the date of the order’s entry and period of authorized interception; and 3) the fact that during the period, wire, oral, or electronic communications were or were not intercepted.

That section also provides that: “The judge, upon the filing of a motion, may in his discretion make available to such person or his counsel for inspection such portions of the intercepted communications, applications and orders as the judge determines to be in the interest of justice.” 18 U.S.C.A. § 2518(8)(d) (Emphasis supplied).

Defendants ordinarily receive transcripts of the conversations that the government intends to use at trial, along with transcripts of any Brady material. Usually those transcripts are of only a fraction of the recorded conversations.

The government typically makes the entire set of intercepted recordings available to defense counsel. But, so far as I am aware, those recordings, though, I assume, in chronological order, otherwise are not indexed. Defense counsel, in other words, has no indication of who spoke to whom when and what they might have discussed.

This means that counsel may have to listen to hundreds, if not thousands of hours of conversations to determine whether something useful might be found. Even where the client, despite the passage of time between interception and indictment, might be able to recall speaking with someone about something pertinent at or around a specific time, such recollection is unlikely to be precise or focused. In which case, counsel probably would have to spend considerable time looking for such conversations.

The call logs give the government a roadmap which makes its access to specific conversations relatively easy and efficient. Those logs should be available to defense counsel to serve the same useful function.

Though § 2518(8)(d) refers to the notice provided under that section as an “inventory,” the notice simply is not as complete or informative as the information routinely provided in the context of a conventional search and seizure. Rule 41(f)(1)(B) of the Federal Rules of Criminal Procedure mandates, on execution of a conventional search warrant, that “[a]n officer present during the execution of the warrant must prepare and verify an inventory of any property seized.” In addition, Rule 41(f)(1)(C) requires “[t]he officer executing the warrant [to] give a copy of the warrant *982 and a receipt for the property taken to the person from whom, or from whose premises, the property was taken or leave a copy of the warrant and receipt at the place where the officer took the property.”

Neither § 2518(8)(d) nor Rule 41 requires anything similar with regard to the material seized through execution of an electronic search under Title III. This is so, even though the circumstances of an electronic search differ significantly from those of a conventional search.

When officers execute a conventional search, the target, if present, knows immediately that the search has occurred. Even if the target is not present, the receipt mandated by Rule 41(f)(1)(C) provides detailed notice as to what has been taken. Moreover, Rule 41(f)(1)(D) requires the officers to return the inventory mandated by subsection (B) to the issuing Magistrate Judge; that judicial officer, in turn, “must, on request, give a copy of the inventory to the person from whom, or from whose premises, the property was taken.” Fed.R.Crim.P. 41(f)(1)(D).

The target of a conventional search thus knows either at the time of the search or shortly thereafter that it has occurred and, even more importantly, what was taken.

Neither is true with an electronic search, which by its nature must be and remain secret until surveillance has ended. Even thereafter, § 2518(8)(d) allows the secrecy to continue for up to three months. Where, as in this case, there has been a series of extension orders, it will be impossible, as a practical matter, for anyone whose conversations the government intercepted to recall what such interception might have “seized.”

As specified in § 2518(8)(d), the contents of the “inventory” provided under that section is such in name only—if even that. This is so, despite the contention in the formal legislative history of Title III, Senate Report 1097, that § 2518(8)(d) reflects existing search warrant practice. S.Rep. No. 1097, at 2194.

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Cite This Page — Counsel Stack

Bluebook (online)
585 F. Supp. 2d 980, 2008 U.S. Dist. LEXIS 93604, 2008 WL 4906001, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-franco-ohnd-2008.