DOJ-OGR-00000661.pdf

Case 1:19-cr-00490-RMB Document 53 Filed 09/03/19 Page 23 of 86 23 1 told that the medical examiner had seen nine minutes of one 2 video which was on a stairwell between floors at the MCC. She 3 was told that the principal video that would have showed the 4 whole hall was corrupted. It was in DC with the FBI to see if 5 they can reconstruct it. 6 And I asked the same questions that my co-counsel did, 7 you know, was the dysfunction of the critical pivotal video, in 8 the most secure prison east of Florence, out in Colorado known 9 to the MCC before August 10, or was this corruption occurring 10 on August 10, which would again cause us to be skeptical of the 11 servitude of the medical examiner's conclusions that this was 12 suicide rather than some other cause. 13 So with my co-counsel, we ask your Honor, it is not a 14 question of trust or not trust. They ask you to detain people 15 and you trust the Bureau of Prisons. And it is within your 16 inherit authority, your Honor, to find out what happened to our 17 client. 18 We are angry about the conditions he was held in. And 19 we're also angry, quite frankly, your Honor, that the only 20 source of information that we get as to what happened to him is 21 through the media rather than through the United States 22 Attorney's office. We've made requests informal. We have 23 made Touhy requests. We've been told there is a pending 24 investigation. 25 But we trust your Honor and the judiciary, and with SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000661