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751 KB
Extraction Summary
5
People
3
Organizations
1
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
751 KB
Summary
This document, an excerpt from a legal filing, discusses the importance of discovery and the production of exculpatory evidence in criminal cases, citing precedents from the Libby and Marshall cases. It details how courts have interpreted Rule 16 regarding material evidence, emphasizing that the government must produce relevant documents even if they originate from other agencies. The text also references a definition of material evidence from the United States v. Lloyd case.
People (5)
| Name | Role | Context |
|---|---|---|
| Valerie Plame |
Mentioned in relation to a 'revenge issue' and as the wife of Ambassador Wilson.
|
|
| Ambassador Wilson | Ambassador |
Identified as Valerie Plame's 'late husband'.
|
| Libby | Defendant |
The defendant in a case where the Court ruled in favor of the defense regarding discovery.
|
| Marshall | Defendant |
The defendant in a drug-related transaction case, found guilty after newly discovered evidence was excluded, and whos...
|
| Lloyd |
A party in the case 'United States v. Lloyd', cited for a definition of material evidence under Rule 16.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court | Government agency |
Refers to the judicial body making rulings and decisions in the Libby, Marshall, and United States v. Lloyd cases.
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| the government | Government agency |
Refers to the prosecution or government agents involved in the cases, arguing points of law and investigating.
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| county public records | Government agency |
Source of local records about a traffic stop in the Marshall case.
|
Timeline (2 events)
Locations (1)
| Location | Context |
|---|---|
|
Where defendant Marshall was incarcerated, and records of visitation were kept.
|
Relationships (1)
Ambassador Wilson is referred to as Valerie Plame's 'late husband'.
Key Quotes (3)
""all agencies""Source
— The Court (implied)
(The focus of the Court's decision in the Libby case, referring to agencies with information regarding offenses.)
DOJ-OGR-00022040.jpg
Quote #1
"'materially exculpatory,'"Source
— The government (argument)
(The government's argument in the Marshall appeal, which the Court rejected, regarding the standard for producing items.)
DOJ-OGR-00022040.jpg
Quote #2
"'as long as there is a strong indication that it will play an important role in uncovering admissible evidence, aiding witness preparation, corroborating testimony, or assisting impeachment or rebuttal.'"Source
— The Court (in United States v. Lloyd)
(The definition of 'material' evidence under Rule 16, as stated by the Court in United States v. Lloyd.)
DOJ-OGR-00022040.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,223 characters)
Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page 17 of 38
far-reaching nature, including documents related to a revenge issue as to Valerie Plame, and her
late husband, Ambassador Wilson. The Court in Libby ruled in favor for the defense and granted
the motion to compel discovery in several key areas of the case.
late husband, Ambassador Wilson. The Court in Libby ruled in favor for the defense and granted
the motion to compel discovery in several key areas of the case.
This Court will find Libby, supra, important because the Court's decision in that case
focused on "all agencies" that have information regarding the offenses charged. In the instant
matter, therefore, it will not be enough for the government to state that other agencies may not be
allied with the prosecution, or that the government lacks access to the documents. If the
documents provide exculpatory evidence, and are related to the issues in the indictment, they
must be produced.
focused on "all agencies" that have information regarding the offenses charged. In the instant
matter, therefore, it will not be enough for the government to state that other agencies may not be
allied with the prosecution, or that the government lacks access to the documents. If the
documents provide exculpatory evidence, and are related to the issues in the indictment, they
must be produced.
In Marshall, 132 F.3d at 63, the defendant was charged in a drug related transaction.
There were records on visitation from the local jail where the defendant was incarcerated, pager
records, the pager, and local records from the county public records about a traffic stop. These
items were uncovered by the government agents investigating the matter, but only after
discovery had been concluded. During the course of the trial, the Court took a four-day
adjournment, in order to address the newly discovered evidence. The trial judge decided to
exclude all of the newly discovered evidence, and, as a result, Marshall was found guilty. On
appeal, the government argued that, in fact, the newly discovered evidence, under Rule 16,
tended to incriminate, not exculpate Marshall. On appeal, the Court disagreed, citing Rule
16(a)(1)(C) as requiring the production of items that are material to the preparation of the
defendant's case. The Court, in addition, rejected the government's argument, that the items
must be 'materially exculpatory,' Id. at 68. In announcing the rule, that Court stated: "In United
States v. Lloyd, we said that evidence is material under Rule 16 'as long as there is a strong
indication that it will play an important role in uncovering admissible evidence, aiding witness
preparation, corroborating testimony, or assisting impeachment or rebuttal.'" See Lloyd at 351.
There were records on visitation from the local jail where the defendant was incarcerated, pager
records, the pager, and local records from the county public records about a traffic stop. These
items were uncovered by the government agents investigating the matter, but only after
discovery had been concluded. During the course of the trial, the Court took a four-day
adjournment, in order to address the newly discovered evidence. The trial judge decided to
exclude all of the newly discovered evidence, and, as a result, Marshall was found guilty. On
appeal, the government argued that, in fact, the newly discovered evidence, under Rule 16,
tended to incriminate, not exculpate Marshall. On appeal, the Court disagreed, citing Rule
16(a)(1)(C) as requiring the production of items that are material to the preparation of the
defendant's case. The Court, in addition, rejected the government's argument, that the items
must be 'materially exculpatory,' Id. at 68. In announcing the rule, that Court stated: "In United
States v. Lloyd, we said that evidence is material under Rule 16 'as long as there is a strong
indication that it will play an important role in uncovering admissible evidence, aiding witness
preparation, corroborating testimony, or assisting impeachment or rebuttal.'" See Lloyd at 351.
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