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Extraction Summary

3
People
4
Organizations
0
Locations
1
Events
2
Relationships
4
Quotes

Document Information

Type: Legal filing / court document (government response/memorandum)
File Size: 716 KB
Summary

This page is from a legal filing (Document 35, filed 04/24/20) in the case against Thomas (likely Michael Thomas, a guard involved in the Epstein case). The prosecution argues that Thomas is not entitled to draft OIG reports under Rule 16 or Brady obligations. Furthermore, the text argues Thomas has failed to meet the burden of proof required to demand discovery to support a 'selective prosecution' claim, specifically failing to prove discriminatory intent or effect regarding his charges relative to rampant conduct within the Bureau of Prisons.

People (3)

Name Role Context
Thomas Defendant
Subject of the legal arguments; seeking discovery regarding 'selective prosecution' and statistics on BOP conduct. (L...
Lewis Cited Case Defendant
referenced in case citation United States v. Lewis.
Armstrong Cited Case Defendant
referenced in case citation Armstrong, 517 U.S. regarding selective-prosecution claims.

Organizations (4)

Name Type Context
DOJ-OIG
Department of Justice Office of the Inspector General; attorneys preparing a report.
BOP
Bureau of Prisons; Thomas alleges certain conduct was 'rampant' throughout this organization.
4th Cir.
United States Court of Appeals for the Fourth Circuit (cited in caselaw).
United States District Court
Implied by case number header Case 1:19-cr-00830-AT.

Timeline (1 events)

2020-04-24
Filing of Document 35 in Case 1:19-cr-00830-AT
Court Record
Prosecution Defense

Relationships (2)

Thomas Employment/Legal BOP (Bureau of Prisons)
Thomas argues conduct he is charged with was 'rampant throughout the BOP'.
Prosecution Information Sharing DOJ-OIG
Prosecution provided underlying materials to DOJ-OIG attorneys preparing the Report.

Key Quotes (4)

"Thomas has not cited a single authority requiring the production of a draft, unpublished report by an inspector general or related work product"
Source
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Quote #1
"Thomas seeks 'information and statistics that show the conduct in which the defendant is being charged with a crime were . . . rampant throughout the BOP'"
Source
DOJ-OGR-00022091.jpg
Quote #2
"Indeed, Thomas has failed to put forth any evidence that his prosecution was the result of discriminatory effect or discriminatory purpose."
Source
DOJ-OGR-00022091.jpg
Quote #3
"nothing contained in [an] OIG report would ordinarily have been discoverable"
Source
DOJ-OGR-00022091.jpg
Quote #4

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