Opinion
Case No: 3:11-cr-00083-15
04-30-2012
UNITED STATES OF AMERICA v. CARLOS FLETCHER
JUDGE HAYNES
MOTION FOR EXCULPATORY EVIDENCE
Comes now the Defendant, Carlos Fletcher by and through counsel, Jim Todd, pursuant to Federal Rule of Criminal Procedure 16 and Brady v. Maryland. 373 U.S. 83 (1963) respectfully requests the Court to ORDER the United States Attorney's Office to disclose any exculpatory evidence.
Defendant would submit that he is a charged co-defendant in a multi defendant conspiracy case. Defendant would submit that given the pleadings that have been submitted in this case it appears that certain co-defendants have provided proffers to the Government. Defendant would submit that based on counsel's experience, it is common during proffers for the Government to illiciate information regarding charged co-defendants.
Defendant respectfully requests the Government to disclose any information received in proffers that is exculpatory to the Defendant.
Respectfully submitted,
___________
JIM TODD #16320
HAGAN & TODD PLLC
218 Third Avenue North
Suite 200
Nashville, TN 37201
Phone: (615) 628-9111