Case 3:20-cr-00248-SCC Document 513 Filed 12/11/23 Page 1 of 6
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO UNITED STATES OF AMERICA, Plaintiff, v. [1] MARIA MILAGROS CHARBONIERLAUREANO, and
Case No. 20-CR-248 (SCC)
[3] ORLANDO MONTES-RIVERA, Defendants. UNITED STATES’ NOTICE OF INTENT TO OFFER SUMMARY EXHIBITS The United States of America, by and through its attorneys, hereby provides notice to the Court and the parties of its intent to rely on Federal Rule of Evidence 1006 to introduce summary exhibits during trial. The government’s proposed summary exhibits are attached to this notice. See Attach. A. Proposed Exhibit 1200 depicts Acevedo’s biweekly salary over time. See id. at 1. Proposed Exhibits 1201 through 1205 summarize Acevedo’s deposit and ATM activities, showing that she routinely deposited a portion of her paycheck into a bank account but retained most of each paycheck in cash. See id. at 2–6. And Proposed Exhibits 1206 through 1210 outline a series of transactions on the cash-transfer app ATH Movil in which Acevedo sent money to Orlando Montes-Rivera and Orlando Montes Charbonier. See id. at 7–11. The proposed summary exhibits will streamline the government’s presentation of evidence and simplify the evidence for the jury’s benefit. Rule 1006 allows a party to “use a summary, chart, or calculation to prove the content of voluminous writings, recordings, or photographs that cannot be conveniently examined in court.”