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735 KB
Extraction Summary
8
People
4
Organizations
1
Locations
3
Events
1
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
735 KB
Summary
This legal document is a filing by the Government arguing that it has fulfilled its discovery obligations under Brady, Giglio, and Rule 16. The Government details the materials it has produced, including records surrounding Epstein's suicide and employee files for Noel and Thomas, and cites legal precedents from the Southern District of New York to support its position that the defendant's motion to compel further discovery should be denied.
People (8)
| Name | Role | Context |
|---|---|---|
| Epstein |
Mentioned in the context of his suicide, with documents like staffing rosters from the period surrounding the event b...
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| Noel |
Mentioned as a subject of employee files and staffing history produced by the Government.
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| Thomas |
Mentioned as a subject of employee files and staffing history produced by the Government.
|
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| Gonzalez | Defendant |
Named in a cited legal case, United States v. Gonzalez, used as precedent.
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| Underwood | Defendant |
Named in a cited legal case, United States v. Underwood, used as precedent.
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| Perez | Defendant |
Named in a cited legal case, United States v. Perez, used as precedent.
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| Brady | Legal Precedent |
Refers to the Brady disclosure rule from Brady v. Maryland, which requires prosecutors to disclose exculpatory evidence.
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| Giglio | Legal Precedent |
Refers to the Giglio rule from Giglio v. United States, which requires prosecutors to disclose information that could...
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Organizations (4)
| Name | Type | Context |
|---|---|---|
| Bureau of Prison | government agency |
Mentioned as the source of written policies and regulations that were produced as evidence.
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| Government | government agency |
The prosecuting party in the case, which is arguing it has complied with its discovery obligations.
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| MCC | correctional facility |
Mentioned as the source of internal phone records related to the case.
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| United States | government |
The plaintiff in the cited legal cases (United States v. Gonzalez, United States v. Underwood, United States v. Perez).
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Timeline (3 events)
Production of discovery materials by the Government in advance of trial.
The Government's investigation during which witnesses were interviewed.
Government
witnesses
Locations (1)
| Location | Context |
|---|---|
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The Southern District of New York, the court where the cited legal precedents were established.
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Key Quotes (2)
"represented that it had complied with and would continue to comply with its Brady and Rule 16 obligations"Source
— the government
(A quote from the ruling in United States v. Gonzalez, describing the government's position in that case, which led to the denial of a motion to compel.)
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Quote #1
"The courts of this Circuit repeatedly have denied pretrial requests for discovery orders pursuant to Brady where the government has made such good faith representations."Source
— Court in United States v. Underwood
(A quote from the ruling in United States v. Underwood, cited as precedent for denying discovery orders when the government asserts compliance in good faith.)
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Quote #2
Full Extracted Text
Complete text extracted from the document (2,154 characters)
Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 14 of 34
that the Indictment relates to a 14-hour time period); count slips, thirty minute round forms, and staffing rosters for the three-week period surrounding Epstein’s suicide; internal MCC phone records; employee files and staffing history for Noel and Thomas; and a wide range of written Bureau of Prison policies and regulations, among other documents and materials. In addition and while not required by Rule 16, the Government produced months in advance of trial (and now, approximately a year in advance of trial) statements for all of the witnesses interviewed during the investigation. While the Government is not aware of any other information that warrants disclosure, it will produce any such materials to the extent it becomes aware of them.
The Government is likewise aware of, and has complied with, its Brady and Giglio obligations. The Government has already produced any evidence in its possession that is arguably exculpatory or impeaching. To the extent Giglio material exists in notes of witness statements or attorney proffers made on behalf of witnesses that have not already been produced, the Government intends to comply with its obligations and will make such disclosures sufficiently in advance of trial to be effectively used. Based on that representation alone, the defendant’s motion should be denied. See United States v. Gonzalez, No. 19 Cr. 123-2 (NRB), 2020 WL 1809293, at *5 (S.D.N.Y. Apr. 9, 2020) (denying a motion to compel because the government “represented that it had complied with and would continue to comply with its Brady and Rule 16 obligations); United States v. Underwood, No. 04 Cr. 424 (RWS), 2005 WL 927012, at *1 (S.D.N.Y. Apr. 21, 2005) (“The courts of this Circuit repeatedly have denied pretrial requests for discovery orders pursuant to Brady where the government has made such good faith representations.”); United States v. Perez, 940 F. Supp. 540, 553 (S.D.N.Y. 1996) (denying defendant’s motion to compel production of Brady based on Government’s representation that it was aware of and had complied with Brady).
The Government is likewise aware of, and has complied with, its Brady and Giglio obligations. The Government has already produced any evidence in its possession that is arguably exculpatory or impeaching. To the extent Giglio material exists in notes of witness statements or attorney proffers made on behalf of witnesses that have not already been produced, the Government intends to comply with its obligations and will make such disclosures sufficiently in advance of trial to be effectively used. Based on that representation alone, the defendant’s motion should be denied. See United States v. Gonzalez, No. 19 Cr. 123-2 (NRB), 2020 WL 1809293, at *5 (S.D.N.Y. Apr. 9, 2020) (denying a motion to compel because the government “represented that it had complied with and would continue to comply with its Brady and Rule 16 obligations); United States v. Underwood, No. 04 Cr. 424 (RWS), 2005 WL 927012, at *1 (S.D.N.Y. Apr. 21, 2005) (“The courts of this Circuit repeatedly have denied pretrial requests for discovery orders pursuant to Brady where the government has made such good faith representations.”); United States v. Perez, 940 F. Supp. 540, 553 (S.D.N.Y. 1996) (denying defendant’s motion to compel production of Brady based on Government’s representation that it was aware of and had complied with Brady).
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DOJ-OGR-00022076
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