CYNTHIA A.

POULSON (5841)
Assistant Attorney General
SEAN D. REYES (7969)
Utah Attorney General
5272 S. College Drive, Second Floor
PO Box 140871
Salt Lake City, Utah 84123
Telephone: (801) 281-1292
Email: cpoulson@agutah.gov

Attorneys for the Plaintiff

IN THE THIRD DISTRICT COURT – WEST JORDAN DEPARTMENT

IN AND FOR SALT LAKE COUNTY, STATE OF UTAH

STATE OF UTAH,
CERTIFICATE OF DISCOVERY
Plaintiff,

vs. Judge L. Douglas Hogan

DOUGLAS EUGENE SALTSMAN, Case No. 191405112

Defendant.

I hereby certify that on January 7, 2020, I caused a copy of discoverable materials, and

this certificate, in the above entitled matter to be hand delivered to Joshua S. Baron, attorney for

the Defendant.

Bates Stamp No. Document

AG000001-000008 Charging documents
AG000009-000072 Versadex report
AG000073 (blu-ray disc) Folders: court docs, evidence,
Douglas Saltsman, reports

A general request for discovery cannot be honored. See State v. Knight, 734 P.2d 913 (Utah

1987). The attached discoverable materials represent all discoverable, non-privileged, non-

protected, materials in the possession of the Prosecutor, as of the date of this response (except as

otherwise indicated). The Utah Attorney General’s Office strictly complies with the mandates of
Rule 16 of the Utah Rules of Criminal Procedure. Other documents or discoverable materials may

or may not exist in individual agency files. You are directed to contact these agencies for such

information.

The State is providing defense counsel information that it is aware of that is relevant to

the charges filed in this case. The State will continue to provide defense counsel with

information that may comply with the discovery request and the State’s ongoing duty.

As is the case in some matters involving Sexual Exploitation of Minors, Enticement of a

Minor, Dealing in Material Harmful to a Minor, and related criminal offenses, there may exist

and the State may possess, some or all of the following listed items. These items have not been

provided and/or are protected. Such discoverable materials will be made available for viewing

and examination by defense counsel, or Defendant’s expert, by making an appointment with the

Assistant Attorney General assigned to this matter.

1. Images, videos, thumbnails, and raw data containing child pornography, received by

direct download during the investigation of this case, located within any of the digital

media or electronic storage devices seized in connection with this case;

2. Images, videos, thumbnails, and raw data that does not contain child pornography,

received by direct download, seized from the Defendant’s computer(s) and/or electronic

storage device(s), and/or contained in some other format, when such images, videos,

thumbnails, or raw data are interspersed with a voluminous amount of child pornography,

making the sorting and providing as discovery unreasonably time consuming, as well as

possibly irrelevant in this matter; and

 3. Strategic plan(s), PowerPoint presentation(s), or other items used for briefing or in

preparation of law enforcement participants involved in the execution of any search

warrant(s) in this matter.

Evidence, if any, which tends to mitigate the guilt of the Defendant, or mitigate the

degree of the offense(s) for reduced punishment is contained in the attached materials or is

otherwise unknown to the prosecutor. Additional discoverable material, if any, received by the

prosecutor subsequent to the date of this response shall be disclosed within a reasonable time

from receipt.

The State has not yet determined the witnesses or exhibits it intends to call or utilize for

trial or in any hearing in this matter. However, please see the included materials for names of

potential witnesses, their contact information, and the matters upon which they may testify.

Furthermore, included in the materials are potential exhibits and evidence the State may seek to

introduce at trial or any hearing in this case. Additional pertinent Brady-Giglio material, if any,

will be provided prior to trial, or upon court order.

Please note that the enclosed materials or any other additional material obtained from the

Utah Attorney General’s Office are restricted from further dissemination to the defendant or

third parties, pursuant to Rule 16(e), Utah Rules of Criminal Procedure. Additionally, said

materials may contain protected records/information only to be used in connection with this

court case, and not for any other purpose.

DATED this 7th day of January, 2020.

/s/ Cynthia A. Poulson

Cynthia A. Poulson
Assistant Attorney General
 CERTIFICATE OF MAILING

I hereby certify that on January 7, 2020, I electronically filed the foregoing with the Clerk
of the Court by using the ECF system which will send a notice of electronic filing to the
following:

Joshua S. Baron
Attorney for Defendant

/s/ Edna Garcia

Legal Secretary