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Extraction Summary

5
People
5
Organizations
2
Locations
2
Events
2
Relationships
4
Quotes

Document Information

Type: Legal filing (government memorandum of law/opposition brief)
File Size: 731 KB
Summary

This page is from a legal filing (Case 1:19-cr-00830-AT) filed on April 24, 2020, involving the prosecution of prison guards (specifically defendant Thomas) related to the events of August 9-10, 2019 (Jeffrey Epstein's suicide). The Government argues against Thomas's request for BOP records regarding staffing shortages and prior instances of falsified records, asserting that the BOP was not part of the prosecution team and therefore the Government is not obligated to search BOP files under discovery rules. The text cites legal precedents (U.S. v. Bryan, U.S. v. Volpe) to support the limitation of 'government' to only those agencies participating in the specific investigation.

People (5)

Name Role Context
Thomas Defendant
Michael Thomas (implied by case number 1:19-cr-00830), seeking discovery records regarding BOP staffing and rounds.
BOP personnel Employees
Mentioned regarding failure to conduct rounds/counts and falsifying records.
Bryan Legal Citation Subject
Referenced in United States v. Bryan case law.
Volpe Legal Citation Subject
Referenced in United States v. Volpe case law.
Libby Legal Citation Subject
Referenced in United States v. Libby case law.

Organizations (5)

Name Type Context
BOP
Bureau of Prisons; Government argues they were not involved in strategic prosecution decisions.
Government
The Prosecution/Department of Justice.
MCC
Metropolitan Correctional Center; location of staffing shortages and missed rounds.
Ninth Circuit
Court of Appeals cited in legal precedent.
IRS
Internal Revenue Service; mentioned in the context of the Bryan case precedent.

Timeline (2 events)

2019-08-09
Events of August 9 and 10, 2019
MCC
2019-08-10
Events of August 9 and 10, 2019
MCC

Locations (2)

Location Context
MCC
Metropolitan Correctional Center (New York), where the events occurred.
Eastern District of New York (mentioned in case citation).

Relationships (2)

Thomas Legal Adversary Government
Thomas seeks order compelling Government; Government opposes.
BOP Institutional Government
Government argues BOP was not involved in strategic decisions or joint investigation for discovery purposes.

Key Quotes (4)

"no BOP personnel accompanied the prosecution to court proceedings."
Source
DOJ-OGR-00022087.jpg
Quote #1
"Thomas has offered no reason to believe that most if not all of the records that he seeks—such as records of other instances of BOP employees failing to conduct rounds and counts—would be part of the BOP’s investigation."
Source
DOJ-OGR-00022087.jpg
Quote #2
"a federal prosecutor need not comb the files of every federal agency which might have documents regarding the defendant"
Source
DOJ-OGR-00022087.jpg
Quote #3
"[c]ourts have construed the term 'government' . . . narrowly to mean the prosecutors in the particular case or the governmental agencies jointly involved in the prosecution of the defendant, and not the ‘government’ in general."
Source
DOJ-OGR-00022087.jpg
Quote #4

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