DOJ-OGR-00022036.jpg
822 KB
Extraction Summary
8
People
3
Organizations
1
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
822 KB
Summary
This document is a legal filing on behalf of a defendant, Mr. Thomas, arguing for the disclosure of evidence related to his criminal charges. The defense contends that rampant staffing shortages and mismanagement by the Bureau of Prisons (BOP) at the Metropolitan Correctional Center (MCC) forced the defendant to engage in the alleged conduct. To support this claim, the filing references an attached memorandum from a union meeting that occurred just three days before Jeffrey Epstein's death at the same facility in August 2019.
People (8)
| Name | Role | Context |
|---|---|---|
| Mr. Thomas | Defendant |
The defendant in the case, for whom this legal motion is being filed to prepare a defense.
|
| Marshall |
Named in the case citation 'United States v. Marshall'.
|
|
| Lloyd |
Named in the case citation 'United States v. Lloyd'.
|
|
| Poindexter |
Named in the case citation 'United States v. Poindexter'.
|
|
| Stein |
Named in the case citation 'United States v. Stein'.
|
|
| George |
Named in the case citation 'United States v. George'.
|
|
| Jeffrey Epstein | Deceased inmate |
Mentioned as having died at the MCC on August 10, 2019, with a relevant union meeting occurring 3 days prior.
|
| Jermaine Darden | Captain of the MCC |
Mentioned as an attendee of a union committee meeting memorialized in an attached memorandum.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| BOP | government agency |
Bureau of Prisons, whose leadership and policies are blamed for the conditions that allegedly led to the defendant's ...
|
| MCC | government facility |
Metropolitan Correctional Center, where staffing shortages allegedly occurred and where Jeffrey Epstein died.
|
| United States | government |
The prosecuting party in several cited legal cases, including against the defendant Mr. Thomas.
|
Timeline (2 events)
Locations (1)
| Location | Context |
|---|---|
|
The location where staffing shortages occurred, where Jeffrey Epstein died, and where Jermaine Darden was captain.
|
Relationships (2)
Mr. Thomas is the defendant in a criminal case being prosecuted by the United States government.
Jermaine Darden is identified as the captain of the MCC.
Key Quotes (3)
"The language and the spirit of the Rule are designed to provide to a criminal defendant, in the interest of fairness, the widest possible opportunity to inspect and receive such materials in the possession of the government as may aid him in presenting his side of the case."Source
— United States v. Poindexter, 727 F. Supp. 1470, 1473 (D.D.C. 1989)
(Quoted to support the argument for a broad interpretation of discovery rules for defendants.)
DOJ-OGR-00022036.jpg
Quote #1
"the “materiality standard normally is not a heavy burden.”"Source
— United States v. Stein, 488 F. Supp. 2d 350, 356 (S.D.N.Y.2007)
(Cited to argue that the threshold for evidence disclosure is not high.)
DOJ-OGR-00022036.jpg
Quote #2
"the materiality hurdle “is not a high one”"Source
— United States v. George, 786 F. Supp. 11, 13 (D.D.C. 1991)
(Cited to further support the argument that the standard for materiality of evidence is low.)
DOJ-OGR-00022036.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,424 characters)
Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page 13 of 38
in uncovering admissible evidence, aiding witness preparation, corroborating testimony, or assisting impeachment or rebuttal.” United States v. Marshall, 132 F.3d 63, 68 (D.C. Cir. 1998) (quoting United States v. Lloyd, 992 F.2d 348, 351 (D.C. Cir. 1993)) (internal quotation marks omitted). Courts have interpreted the scope of Rule 16 (a)(1)(E)(i) broadly to ensure that defendants such as Mr. Thomas have a fair opportunity to prepare for trial. United States v. Poindexter, 727 F. Supp. 1470, 1473 (D.D.C. 1989) (“The language and the spirit of the Rule are designed to provide to a criminal defendant, in the interest of fairness, the widest possible opportunity to inspect and receive such materials in the possession of the government as may aid him in presenting his side of the case.”) Accordingly, the “materiality standard normally is not a heavy burden.” United States v. Stein, 488 F. Supp. 2d 350, 356 (S.D.N.Y.2007) (quoting United States v. Lloyd, 992 F.2d 348, 351 (D.C.Cir.1993)). Lloyd, 992 F.2d at 351 (internal citation and quotation marks omitted); United States v. George, 786 F. Supp. 11, 13 (D.D.C. 1991) (the materiality hurdle “is not a high one”). The requested documents in this motion are essential to Mr. Thomas’ ability to prepare a defense. Mr. Thomas contends that the conduct with which he is being charged is: 1) rampant throughout the BOP; 2) made with knowledge and acquiescence by the leadership of the BOP; and 3) is the direct result of BOP policies and mismanagement that forced the defendant to engage in conduct for which he is now being charged criminally. Moreover, the information sought in this motion is crucial to the preparation of Mr. Thomas’ defense. For instance, Mr. Thomas will assert that the rampant staffing shortages present at the MCC in August of 2019 led to the conduct for which Mr. Thomas is now criminally charged. If the Court accepts this representation, then the Court should find that the discovery requests contained in this motion are “material” and must be disclosed. As support for this position the defendant has attached an excerpt from a union committee meeting that was held merely 3 days before Jeffrey Epstein died at MCC on August 10, 2019. The attached memorandum memorializes a meeting attended by Jermaine Darden, the captain of the MCC, wherein he was
DOJ-OGR-00022036
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document