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711 KB
Extraction Summary
4
People
6
Organizations
1
Locations
4
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
711 KB
Summary
This legal document is a filing by the Government arguing against a motion from a defendant named Thomas. The Government contends it is not required to produce documents from separate investigations conducted by the Bureau of Prisons (BOP) or other federal agencies into the death of Jeffrey Epstein, because those agencies are not part of the prosecution team and the materials are not in the prosecution's possession.
People (4)
| Name | Role | Context |
|---|---|---|
| Thomas | Defendant |
Mentioned as the individual whose motion is being discussed, requesting documents from the Government.
|
| Jeffrey Epstein |
Mentioned in the context of his death, which was investigated by federal agencies.
|
|
| Brady |
Referenced in the context of a legal rule (Brady rule) regarding the disclosure of evidence.
|
|
| Giglio |
Referenced in the context of a legal rule (Giglio v. United States) regarding the disclosure of evidence.
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Refers to the prosecution team in the legal case.
|
| BOP | government agency |
Abbreviation for the Bureau of Prisons, which conducted a separate investigation.
|
| MCC | government agency |
Abbreviation for the Metropolitan Correctional Center, whose employees are mentioned in a request for records.
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| U.S. Marshal Service | government agency |
Abbreviated as "USMS", mentioned as having potentially conducted an investigation based on a CNN article.
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| CNN | company |
Mentioned as the source of an article claiming the U.S. Marshal Service conducted an investigation.
|
| Court | government agency |
The judicial body being addressed in the motion.
|
Timeline (4 events)
Investigations by federal agencies into the circumstances surrounding the death of Jeffrey Epstein.
any other federal agencies
An alleged investigation conducted by the U.S. Marshal Service, which the Government claims was not done in coordination with the prosecution.
The death of Jeffrey Epstein.
Locations (1)
| Location | Context |
|---|---|
|
Metropolitan Correctional Center, a federal jail whose employees are subject to a records request.
|
Relationships (3)
Thomas is the defendant making a motion, and the Government is the prosecution arguing against it.
The document explicitly states, "The BOP is not, and never has been, part of the prosecution team."
The document states that any inquiry by the USMS "was not conducted jointly or in coordination with the prosecution team."
Key Quotes (3)
"any reports, witness statements, memorandum, and documents from any separate investigation conducted by the BOP,"Source
— Thomas
(Quoted from Thomas's motion requesting documents from the Government.)
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Quote #1
"documents, reports, witness statements and disciplinary records of any and all MCC employees who have engaged in the same or similar conduct,"Source
— Thomas
(Quoted from Thomas's motion requesting documents from the Government.)
DOJ-OGR-00022082.jpg
Quote #2
"any other federal agencies that investigated the circumstances surrounding the death of Jeffrey Epstein."Source
— Thomas
(Quoted from Thomas's motion requesting documents from the Government.)
DOJ-OGR-00022082.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,066 characters)
Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 20 of 34
irrelevant matters, such as what “led” him to the criminal conduct or the broader “context” in which he committed specific criminal acts. There is no basis to compel production of evidence related to those matters under Rule 16, Brady, or Giglio because they are not material and because the evidence sought is in furtherance of a transparent attempt at nullification. Thomas’s motion should be denied on this basis alone.
C. The Government is Not Required to Collect Materials From Agencies Who Were Not Part of the Prosecution Team
Thomas asks the Court to compel the Government to produce “any reports, witness statements, memorandum, and documents from any separate investigation conducted by the BOP,” “documents, reports, witness statements and disciplinary records of any and all MCC employees who have engaged in the same or similar conduct,” and any previously undisclosed reports, witness statements, and documents created by “any other federal agencies that investigated the circumstances surrounding the death of Jeffrey Epstein.” (Mot. 4, 7 (emphasis added)). Even if Thomas had satisfied the materiality requirement under Rule 16 or Brady with respect to these items—and he has not—Thomas’s motion would still fail because the materials he seeks are not in the prosecution team’s possession.
The BOP is not, and never has been, part of the prosecution team. Nor did the BOP conduct an investigation jointly or in coordination with the prosecution team.⁶ To require the Government to obtain and produce any records from the BOP from a separate investigation, as well as evidence that would support Thomas’s purported (and improper, for the reasons discussed in Part II.B,
⁶ The defendant claims, based on a CNN article, that the U.S. Marshal Service (“USMS”) conducted an investigation. The Government is unaware of such an investigation, and in any event, any such inquiry by the USMS was not conducted jointly or in coordination with the prosecution team.
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