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Extraction Summary

6
People
3
Organizations
1
Locations
2
Events
2
Relationships
6
Quotes

Document Information

Type: Legal document
File Size: 729 KB
Summary

This legal document is a section of a government filing arguing against a defendant's (Thomas) request for certain records. The government contends that the records—related to BOP staffing, policies, and other employees—are not 'material' to preparing a legal defense under Rule 16. Instead, the government asserts Thomas seeks these records for the impermissible purpose of encouraging jury nullification by arguing that poor conditions at the BOP 'led' to his alleged criminal conduct.

People (6)

Name Role Context
Thomas Defendant
The subject of the motion, seeking records for his defense.
Brady
Referenced in the context of the legal precedent 'Brady' material (exculpatory evidence).
Rigas
A party in the cited case 'United States v. Rigas'.
McGuinness
A party in the cited case 'United States v. McGuinness'.
Stevens
A party in the cited case 'Stevens'.
Armstrong
A party in the cited case 'United States v. Armstrong'.

Organizations (3)

Name Type Context
Government government agency
The prosecuting party in the case against Thomas.
BOP government agency
Bureau of Prisons, mentioned in relation to policies, staffing, and employees.
Supreme Court government agency
Mentioned for its holding in the case United States v. Armstrong.

Timeline (2 events)

2020-04-24
Document 35 was filed in Case 1:19-cr-00830-AT.
Defendant Thomas filed a motion seeking records related to BOP staffing, working conditions, and policies.

Locations (1)

Location Context
Southern District of New York, the court district for cited cases.

Relationships (2)

Thomas adversarial (legal) Government
Thomas is the defendant in a criminal case being prosecuted by the Government.
Thomas professional BOP
The document implies Thomas is a BOP employee by mentioning his request for records on BOP policies and other BOP employees.

Key Quotes (6)

"The Requested Records Are Not “Material” to Preparing a Defense and Are Sought for the Impermissible Purpose of Jury Nullification"
Source
— Government (Section header outlining the Government's main argument.)
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Quote #1
"led"
Source
— Thomas (as characterized by the Government) (The Government claims Thomas will argue that BOP conditions 'led' to his criminal conduct.)
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Quote #2
"is material to preparing the defense."
Source
— Fed. R. Crim. P. 16(a)(1)(E) (The legal standard for discoverable items under Rule 16.)
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Quote #3
"It is [a defendant’s] burden to make a prima facie showing that documents sought under Rule 16(a)(1)(E)(i) are material to preparing the defense."
Source
— United States v. Rigas (A quote from a court case establishing the defendant's burden of proof for discovery requests.)
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Quote #4
"if it could be used to counter the Government’s case or bolster a defense."
Source
— Stevens case (The definition of what is 'material to preparing the defense' under Rule 16.)
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Quote #5
"offer more than the conclusory allegation that the requested evidence is material."
Source
— Rigas case (A requirement for a defendant seeking discovery, stating they must provide more than a simple claim of materiality.)
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Quote #6

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