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725 KB
Extraction Summary
9
People
5
Organizations
1
Locations
1
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal filing / government memorandum of law
File Size:
725 KB
Summary
This document is page 19 of a legal filing (Document 35) from case 1:19-cr-00830-AT, filed on April 24, 2020. It contains the Government's legal argument opposing discovery requests made by the defendant, Thomas (likely Michael Thomas, a guard involved in the Epstein jail case). The Government argues that Thomas's requests are irrelevant to the charges and are instead an attempt to 'garner sympathy' and argue 'jury nullification,' citing various legal precedents to support the exclusion of such evidence.
People (9)
| Name | Role | Context |
|---|---|---|
| Thomas | Defendant |
Subject of the government's argument regarding discovery requests and jury nullification efforts. (Context: Likely Mi...
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| Reese | Defendant (Case Citation) |
Cited in legal precedent regarding nullification (933 F. Supp. 2d).
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| Levin | Defendant (Case Citation) |
Cited in legal precedent (2016 WL 2990831).
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| Armstrong | Defendant (Case Citation) |
Cited in relation to selective prosecution claims (517 U.S. at 462-63).
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| Delacruz | Defendant (Case Citation) |
Cited regarding rejection of general information demands (No. 14 Cr. 815).
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| Floyd | Defendant (Case Citation) |
Cited regarding rejection of discovery requests for background data (No. 99 Cr. 0234).
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| Defreitas | Defendant (Case Citation) |
Cited regarding factual impossibility defense (2011 WL 317964).
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| Manzano | Defendant (Case Citation) |
Cited regarding the court's duty to prevent jury nullification (945 F.3d at 627).
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| Rosado | Defendant (Case Citation) |
Cited regarding political defenses and criminal intent (728 F.2d 89, 93).
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| Government |
The party opposing Thomas's discovery requests.
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| NYPD |
New York City Police Department, mentioned in the Floyd case citation.
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| S.D.N.Y. |
Southern District of New York, mentioned in citations.
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| 2d Cir. |
Second Circuit Court of Appeals, mentioned in Rosado citation.
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| DOJ-OGR |
Department of Justice Office of Government Relations (indicated in Bates stamp).
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Timeline (1 events)
Locations (1)
| Location | Context |
|---|---|
|
Implied by S.D.N.Y. and NYPD references.
|
Relationships (1)
Thomas is the defendant seeking discovery; the Government is arguing that his requests amount to an attempt at jury nullification.
Key Quotes (5)
"Thomas’s efforts to garner sympathy, put the Government on trial, and deflect blame for his own criminal actions plainly sound in nullification."Source
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Quote #1
"Evidence on those points does not relate to whether the defendant committed the crimes charged, but rather is intended to elicit sympathy, compassion, or compromise from the jury."Source
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Quote #2
"The records Thomas seeks are no more discoverable than the nullification evidence precluded in Armstrong and its progeny."Source
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Quote #3
"It is the Court’s “duty to forestall or prevent” jury nullification."Source
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Quote #4
"erroneous assumption that good motive for committing a crime is inconsistent with criminal intent"Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,131 characters)
Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 19 of 34
were not on trial).
Thomas’s efforts to garner sympathy, put the Government on trial, and deflect blame for his own criminal actions plainly sound in nullification. See Reese, 933 F. Supp. 2d at 583-84; Levin, 2016 WL 2990831, at *12. Evidence on those points does not relate to whether the defendant committed the crimes charged, but rather is intended to elicit sympathy, compassion, or compromise from the jury. The records Thomas seeks are no more discoverable than the nullification evidence precluded in Armstrong and its progeny. See Armstrong, 517 U.S. at 462-63 (defendant not entitled to discovery on race of other narcotics defendants to aid in selective prosecution claim); United States v. Delacruz, No. 14 Cr. 815 (KBF), 2015 WL 2211943, at *4 (S.D.N.Y. May 12, 2015) (rejecting defendant’s “demands for general information and statistics relating to the Government’s use of sting operations”); United States v. Floyd, No. 99 Cr. 0234 (DAB), 1999 WL 476438, at *2 (S.D.N.Y. July 7, 1999) (rejecting discovery request for “background data, records and investigative reports” of the New York City Police Department (“NYPD”) as well as information about NYPD officers’ conduct in other cases); Defreitas, 2011 WL 317964, at *10 (rejecting discovery demands related to a “factual impossibility” defense to a conspiracy charge). It is the Court’s “duty to forestall or prevent” jury nullification. Manzano, 945 F.3d at 627 (holding that “District courts have a duty to forestall or prevent [jury nullification arguments] and the district court in this case abdicated its duty by ruling that defense counsel could argue jury nullification.”); see also United States v. Rosado, 728 F.2d 89, 93 (2d Cir. 1984) (criticizing trial court for inviting nullification by permitting the defendants to mount a “political defense” and stating that it was an “erroneous assumption that good motive for committing a crime is inconsistent with criminal intent”).
In sum, much of the additional discovery Thomas seeks in his motion relates to legally
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DOJ-OGR-00022081
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