06-14-2016 ecf 697-1 motion to compel production of information regarding law enforcement's use and...

7/26/2019 06-14-2016 ECF 697-1 Motion to Compel Production of Information Regarding Law Enforcement's Use and Display of Force - Exhibit 1

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Case 3:16 cr 00051 BR Document 697 1 Filed 06/14/16 Page 7 of 11


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MJK Discovery 169

For the purposes

o

this memorandum discovery

or

discoverable information includes information required to be disclosed

by Fed.R.Crim.P. 16 and 26.2 the Jencks Act Brady nd Giglio and additional information disclosable pursuant to USAM

9-5.001.

2

How

to

conduct the review

is

discussed below.

3

Exceptions to a prosecutors access to Department law enforcement agencies files are documented

in

agency policy and

may include for example access to a non-testifying sources files.

4

Nothing

in

this guidance alters the Departments Policy Regarding the Disclosure to Prosecutors

o

Potential Impeachment

Information Concerning Law Enforcement Agency Witnesses contained

in

USAM 9-5.100.

5

Interview as used herein refers to a formal question and answer session with a potential witness conducted for the purpose

o obtaining information pertinent to a matter or case. It does not include conversations with a potential witness for the

purpose o scheduling or attending to other ministerial matters. Potential witnesses may provide substantive information

outside

o

a formal interview however . Substantive case-related communications are addressed above.

6

n

those instances

in

which

an

interview was audio or video recorded further memorializat ion will generally not be

necessary.

Updated September 9 2014

Case 3:16-cr-00051-BR Document 697-1 Filed 06/14/16 Page 7 of 11


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Case 3:16-cr-00051-BR Document 697-1 Filed 06/14/16 Page 11 of 11


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MJK Discovery 174

Memorandum for Department Prosecutors

Subject: Issuance o Guidance and Summary o Actions Taken in Response

to the Report o the Department o Justice Criminal Discovery and

Case Management Working Group

Page 4

Revitalize the Computer Forensics Working Group to address the problem o

properly cataloguing electronically stored information recovered as part

o

federal

investigations;

Create a pilot case management project to fully explore the available case

management software and possible new practices to better catalogue law

enforcement investigative files and to ensure that all the information is

transmitted

n

the most useful way to federal prosecutors.

These efforts will be overseen by an attorney detailed to Washington to assure timely completion

o all o these measures.

All

o

the steps that the Department

s

taking are intended to ensure that we have the

resources training and guidance to meet our obligations and that we thoroughly and thoughtfully

evaluate our discovery obligations

n

every case in a manner that facilitates our sole function-to

seek justice. Thank n you in advance for your cooperation in this effort.

06-14-2016 ecf 697-1 motion to compel production of information regarding law enforcement's use and...

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