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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.