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767 KB
Extraction Summary
5
People
4
Organizations
2
Locations
1
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
767 KB
Summary
This legal document, part of a court filing, argues for a broad interpretation of the prosecution's 'Brady obligations.' It asserts that the government must disclose not only admissible favorable evidence but any information that could lead to such evidence, resolving any doubts in favor of disclosure to the defense. The document cites several legal precedents, including Safavian and Paxson, to support the claim that the pretrial standard is simply whether evidence is favorable, not whether it would change the trial's outcome.
People (5)
| Name | Role | Context |
|---|---|---|
| Brady |
Mentioned in the context of the legal precedent 'Brady obligations' or 'Brady disclosure', which requires prosecutors...
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| Giglio |
Cited in the legal case 'Giglio v. United States'.
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| Safavian |
Cited in the legal case 'Safavian', which explained the materiality standard under Brady.
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| Sudikoff |
Cited in the legal case 'United States v. Sudikoff'.
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| Paxson |
Cited in the legal case 'United States v. Paxson'.
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Organizations (4)
| Name | Type | Context |
|---|---|---|
| BOP | government agency |
Mentioned as the 'BOP internal affairs division', which may maintain internal reports.
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| FBI | government agency |
Mentioned as conducting a contemporaneous investigation with other government agencies.
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| Inspector General | government office |
Mentioned in reference to an 'Inspector General's report' that may contain exculpatory statements.
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| United States | government |
Party in several cited court cases, such as 'Giglio v. United States', 'United States v. Sudikoff', and 'United State...
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Timeline (1 events)
2019-08-10
One or both of the defendants in the indictment may have conducted rounds or inmate counts.
defendants
Relationships (1)
prosecution/government
→
legal/adversarial
→
defense
The document outlines the legal obligation of the prosecution (government) to disclose all potentially favorable evidence to the defense under the Brady rule.
Key Quotes (3)
"that is likely to lead to favorable evidence that would be admissible."Source
— United States v. Sudikoff
(Quoted from the Safavian case, describing the scope of evidence the prosecution must produce.)
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Quote #1
"Where doubt exists as to the usefulness of the evidence to the defendant, the government must resolve all such doubts in favor of full disclosure."Source
— United States v. Paxson
(Quoted to support the argument that the government must interpret its Brady obligations broadly.)
DOJ-OGR-00022042.jpg
Quote #2
"[T]he government must always produce any potentially exculpatory or otherwise favorable evidence without regard to how the withholding of such evidence might be viewed-- with the benefit of hindsight--as affecting the outcome of the trial. The question before trial is not whether the government thinks that disclosure of the information or evidence it is considering withholding might change the outcome of the trial going forward, but whether the evidence is favorable and therefore must be disclosed."Source
— The court in Safavian
(A quote explaining the materiality standard under Brady for pretrial discovery.)
DOJ-OGR-00022042.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,257 characters)
Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page 19 of 38
“favorable” under Brady and must be disclosed by the government. Id. at 676-77; see also Giglio v. United States, 405 U.S. 150, 154-55 (1972); In re Sealed Case No. 99-3096 (Brady Obligations), 185 F.3d 887, 892 (D.C. Cir. 1999). Moreover, the defense is already in possession of witness statements that one or both of the defendants in this indictment may have conducted rounds or inmate counts on August 10, 2019. Accordingly, there is a logical assumption that there might be additional exculpatory statements contained in the Inspector General’s report or certain internal reports maintained by the BOP internal affairs division or other government agencies that were conducting a contemporaneous investigation with FBI.
The prosecution must produce to the defense not only all favorable evidence that is admissible, but also all evidence “that is likely to lead to favorable evidence that would be admissible.” Safavian, 233 at 17 (quoting United States v. Sudikoff, 36 F. Supp. 2d 1196, 1198-99 (C.D.Cal. 1999)). Just as with Rule 16 disclosure, the government must interpret its Brady obligations broadly. “Where doubt exists as to the usefulness of the evidence to the defendant, the government must resolve all such doubts in favor of full disclosure.” Id. (citing United States v. Paxson, 861 F.2d 730, 737 (D.C. Cir. 1988). Without question, the Brady disclosure obligation is broader than Rule 16 because it requires production not just of documents, but also of information known to the government that has been documented in some fashion.
In Safavian, the court explained the materiality standard under Brady that applies to pretrial discovery:
[T]he government must always produce any potentially exculpatory or otherwise favorable evidence without regard to how the withholding of such evidence might be viewed-- with the benefit of hindsight--as affecting the outcome of the trial. The question before trial is not whether the government thinks that disclosure of the information or evidence it is considering withholding might change the outcome of the trial going forward, but whether the evidence is favorable and therefore must be disclosed.
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