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730 KB
Extraction Summary
3
People
4
Organizations
1
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Court filing / legal brief (case 1:19-cr-00830-at)
File Size:
730 KB
Summary
This document is page 5 of a court filing (Document 35) from April 24, 2020, in the case against prison guards Noel and Thomas (Case 1:19-cr-00830-AT). It details legal maneuvering regarding discovery, specifically focusing on requests for MCC video surveillance footage and reports from the Inspector General. The text notes that Thomas considered filing a motion to dismiss based on 'selective prosecution' but failed to do so by the deadline.
People (3)
| Name | Role | Context |
|---|---|---|
| Noel | Defendant |
Submitted a letter on Jan 29 seeking materials related to the MCC video surveillance system.
|
| Thomas | Defendant |
Renewed request for Inspector General report information; submitted discovery request regarding BOP and charging deci...
|
| The Court | Judge/Judiciary |
Directed Thomas to file a motion formalizing his request.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States Inspector General |
Entity possessing statements, photos, videos, and incident reports; subject of discovery requests.
|
|
| MCC |
Metropolitan Correctional Center; location associated with the video surveillance system discussed.
|
|
| Government |
Prosecution; responding to discovery requests and producing materials.
|
|
| BOP |
Bureau of Prisons; entity from which Thomas sought information regarding other correctional officers.
|
Timeline (2 events)
Locations (1)
| Location | Context |
|---|---|
|
Metropolitan Correctional Center (implied location of surveillance video).
|
Relationships (2)
Referenced together as 'defendants' in the context of discovery requests.
Thomas requesting discovery from Government; Government responding to requests.
Key Quotes (4)
"Noel’s January 29 letter sought materials related to the MCC video surveillance system and additional surveillance video"Source
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Quote #1
"Thomas, through counsel, renewed his request for “whatever investigation was done and whatever information there is that is discoverable with respect to the Inspector General’s report.”"Source
DOJ-OGR-00022072.jpg
Quote #2
"Thomas, through counsel, previewed that he would also likely file a motion to dismiss the indictment based on “selective prosecution.”"Source
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Quote #3
"Thomas has failed to timely file a motion to dismiss."Source
DOJ-OGR-00022072.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,182 characters)
Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 10 of 34
written statements, photos, videos, and incident reports created, manufactured or possessed by the
United States Inspector General.” Noel’s January 29 letter sought materials related to the MCC
video surveillance system and additional surveillance video, as well as assistance locating
particular information in the surveillance video footage that the Government had previously
produced in discovery.
United States Inspector General.” Noel’s January 29 letter sought materials related to the MCC
video surveillance system and additional surveillance video, as well as assistance locating
particular information in the surveillance video footage that the Government had previously
produced in discovery.
At the pretrial conference the following day, Thomas, through counsel, renewed his request
for “whatever investigation was done and whatever information there is that is discoverable with
respect to the Inspector General’s report.” (Conf. Tr., Jan. 30, 2020, at 6, 9). The Court directed
Thomas to file a motion formalizing his request. (Id. at 9).⁵
for “whatever investigation was done and whatever information there is that is discoverable with
respect to the Inspector General’s report.” (Conf. Tr., Jan. 30, 2020, at 6, 9). The Court directed
Thomas to file a motion formalizing his request. (Id. at 9).⁵
The Government responded to the defendants’ discovery requests by letter dated March
14, 2020. As for Thomas’s request for materials related to any forthcoming Inspector General’s
report, the Government referred Thomas to its prior response as stated at the November 25, 2019
pretrial conference. With respect to Noel’s requests for additional materials related to the MCC
video surveillance system, the Government explained that to the extent such materials were in the
Government’s possession and currently subject to disclosure, they had already been produced. In
addition, the Government provided additional information answering certain of Noel’s questions,
including video timestamps to assist with review of the surveillance footage.
14, 2020. As for Thomas’s request for materials related to any forthcoming Inspector General’s
report, the Government referred Thomas to its prior response as stated at the November 25, 2019
pretrial conference. With respect to Noel’s requests for additional materials related to the MCC
video surveillance system, the Government explained that to the extent such materials were in the
Government’s possession and currently subject to disclosure, they had already been produced. In
addition, the Government provided additional information answering certain of Noel’s questions,
including video timestamps to assist with review of the surveillance footage.
On March 27, 2020, Thomas submitted another discovery request to the Government,
seeking, among other things, information from the BOP regarding other correctional officers and
information about the Government’s charging decisions. The Government responded by letter
seeking, among other things, information from the BOP regarding other correctional officers and
information about the Government’s charging decisions. The Government responded by letter
____________________
⁵ Thomas, through counsel, previewed that he would also likely file a motion to dismiss
the indictment based on “selective prosecution.” (Conf. Tr., Jan. 30, 2020 at 6). The deadline for
filing motions, which was extended at counsel’s request, has passed, and Thomas has failed to
timely file a motion to dismiss.
⁵ Thomas, through counsel, previewed that he would also likely file a motion to dismiss
the indictment based on “selective prosecution.” (Conf. Tr., Jan. 30, 2020 at 6). The deadline for
filing motions, which was extended at counsel’s request, has passed, and Thomas has failed to
timely file a motion to dismiss.
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DOJ-OGR-00022072
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