progressed, the government minimized a greater percentage of calls, in keeping with the approach approved in United, States v. Hyde. Moreover, many of the intercepted calls about which Brown com plain § 3500 (2002). 25 . See United States v. Martinez, 87 F.3d 731, 734 (5th Cir.1996). 26 . 18 U.S.C. § 3500(b). 27 . 18 U.S.C. § 3500(e)(1). 28 . Goldberg v. United States, 425 U.S. 94, 104, 96 S.Ct. 1338, 47 L.Ed.2d 603 (1976) (quoting S.Rep. No. 981, 85th Cong. 3 (1957)) (internal quotation marks omitted). 29 . 565 F.2d 362, 363 (5th Cir.1978). 30 . Id. 31 . Id. 32 . Id. 33 . Id. 34 . Id. at 363-64. 35 . Id. (quoting United States v. Pacheco, 489 F.2d 554, 566 (5th Cir.1974)) (internal quotation marks omitted); See also United States v. Ramirez, 954 F.2d 1035, 1038-39 (5th Cir.1992) (<HOLDING>). 36 . See United States v. Ramirez, 174 F.3d
holding that a police officers notes were relevant as prior and possibly inconsistent statements made and recorded by the witness holding that an fbi agents rough notes of an interview of the defendant were not brady material because there was no independent showing that they contained evidence that was material to the defendants guilt or innocence holdingthat a nurses progress notes were not admissible under the business records exception to the hearsay rule because while the nurses business duty to accurately record plaintiffs behavior ensured the accuracy of her notes it did not guarantee the accuracy of information provided to her by others not under a similar duty holding that agents rough notes were not statements under the jencks act where notes were scattered and all the information contained in them was available to the defendant in other forms holding that an fbi agents notes were not a witness statement within the act because there was no evidence that the witness adopted or approved what was recorded