DOJ-OGR-00022034.jpg
664 KB
Extraction Summary
4
People
3
Organizations
0
Locations
1
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
664 KB
Summary
This document is a legal motion filed on April 9, 2020, in a criminal case on behalf of Defendant Thomas. The defense requests the court to compel the prosecution to turn over various documents and reports, arguing they contain exculpatory evidence under Rule 16 and Brady-Giglio. The motion claims the defendant's alleged criminal conduct was a result of widespread practices and policies within the Bureau of Prisons (BOP) and that the government has unfairly refused to disclose this relevant information.
People (4)
| Name | Role | Context |
|---|---|---|
| Thomas | Defendant |
Mentioned as the defendant who believes requested documents contain exculpatory information and is seeking informatio...
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| FBI investigators | Investigator |
Mentioned as having submitted reports in the case, but potentially not possessing all relevant witness statements.
|
| government prosecutors | Prosecutor |
Mentioned in relation to the potential discriminatory application of BOP policies.
|
| counsel | Defense counsel |
Mentioned as needing to review the government's response to the motion to determine future legal actions.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| FBI | Government agency |
Mentioned in the context of reports submitted by its investigators.
|
| BOP | Government agency |
Abbreviation for Bureau of Prisons. The defendant's alleged conduct is claimed to be related to BOP policies, leaders...
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| Court | Judicial body |
Referenced as the entity that would enter an order on the motion.
|
Relationships (2)
The document is a motion filed by the defendant (Thomas) against the government in a criminal case (Case 1:19-cr-00830-AT).
investigative or disciplinary agencies
→
Professional
→
prosecution
The document describes these agencies as being "allied with the prosecution".
Key Quotes (2)
"Defendant, Thomas, believes that the information contained in all of the requested documents may contain information that tends to exculpate him."Source
— Defense counsel (on behalf of Thomas)
(This quote states the core belief and justification for the discovery motion.)
DOJ-OGR-00022034.jpg
Quote #1
"The present motion is filed at this time because the government has refused the defendant's request to engage in a fair and impartial disclosure of relevant discovery."Source
— Defense counsel
(This quote explains the reason for filing the motion, citing the government's refusal to voluntarily provide the requested information.)
DOJ-OGR-00022034.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (1,868 characters)
Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page 11 of 38
3. As to both defendants, any and all reports, memorandums, written statements, photos, videos, and incident reports created, manufactured or possessed by any investigative or disciplinary agencies, participating in the investigation of the defendants, allied with the prosecution, and to which the prosecution has access
Defendant, Thomas, believes that the information contained in all of the requested documents may contain information that tends to exculpate him. He believes, in addition, that there may be other witnesses, or witness statements that are relevant, and which are not in the possession of the FBI investigators, who submitted reports in this case. Such reports will contain detailed information and statistics that show the conduct in which the defendant is being charged with a crime were: 1) rampant throughout the BOP; 2) made with knowledge and acquiescence by the leadership of the BOP; 3) made as a result of BOP policies that forced the defendant to engage in conduct for which he is now being charged criminally, and; 4) made in a manner which contains a possible discriminatory application of BOP policies by government prosecutors.
The information requested by this motion is not the only information that Mr. Thomas seeks under Rule 16 and Brady-Giglio. Further discovery motions will be necessary, once counsel has had the opportunity to review any response made by the government, in compliance with any order entered by this Court on this motion. The present motion is filed at this time because the government has refused the defendant's request to engage in a fair and impartial disclosure of relevant discovery. Early resolution of this dispute will enable defense counsel to determine the necessity and scope of pretrial subpoenas duces tecum.
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DOJ-OGR-00022034
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