Thursday, December 2, 2021


President Maduro and Alex Saab Moran

Contained in the Government's response to the Court's Standing Discovery Order is a notice, which appears below, that it will present what is known as Uncharged Criminal Conduct to the jury at his trial, which is permitted by Rule 404 of the criminal rules of procedure. This means that other crimes that the defendant allegedly committed will be entered into evidence, a tactic which will most certainly signal to them that he is indeed a career criminal. It will most likely have significant impact.  The complete text appears below.

"The government will timely advise the defendant of its intent, if any, to introduce at trial extrinsic act evidence pursuant to F.R.E. 404(b). Pursuant to Local Rule 88.10, the notice will be provided regardless of whether the evidence may be used in the case-in-chief, for impeachment or possible rebuttal, and will include the general nature of the evidence. You are hereby on notice that all evidence made available to you for inspection, as well as all statements disclosed herein or in any future discovery letter, may be offered in the trial of this cause, under F.R.E. 404(b) or otherwise (including the inextricably-intertwined doctrine). 

In addition, the government may introduce under Rule 404(b) evidence underlying the defendant's past bad acts which include prior payments to Bolivarian Republic of Venezuela officials in order to obtain improper business advantages and access Venezuela’s government-controlled foreign currency exchange system. 

Those prior bad acts also include post-indictment bribing of Venezuelan officials to obtain and retain contracts and other business advantages, including obtaining multi-million dollar food and medicine contracts with entities and instrumentalities owned and Case 1:19-cr-20450-RNS Document 77 Entered on FLSD Docket 11/29/2021 Page 2 of 4 3 controlled by the Venezuelan government for the importation and delivery of food and medicine to the people of Venezuela, and to launder bribes, proceeds, and other funds related to the corrupt scheme into and through accounts in the United States in order to promote the illegal bribery scheme and to conceal the nature and purpose of the proceeds of the illegal bribery scheme, including, but not limited to acts described in Southern District of Florida criminal case, 21-CR-20509-MARTINEZ". 

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