‘STATE OF MARYLAND + INTHE © pistricr court + FOR * BALTIMORE CITY -CABSAR GOODSON + CASENO, 602294452. GARRETT MILLER * CASE. 380294449 EDWARD NERO. * — CASENO. 4B02294450 WILLIAM PORTER * CASENO, 0802294453 BRIAN RICE * CASENO, 2802294448 ALICA WHITE + CASENO, sBo2294451 Defendants . * Jone momioy To pisMiss AND INTHE ALTERNATIVE FOR RECUSALOF ‘BALTIMORE CITY STATI’S ATTORNEY'S OFFICE, Defendants, Caesar Goodson, Garrett Miller, Edward Nero, William Porter, Brian Scott Rice and Alicia White, by respective undersigned counsel, hereby file this Joint Motion to Dismiss and, in the Alternative, for Recusal of the Baltimore City State's Attomey's Office in the prosecution ofeach of their respective cases and in support thereof states: INTRODUCTION ‘On May 1, 2015, in the fave of the threat of continued rots, protests, a city curfew, and civil unrest, the State's Attomey for Baltimore City, Mrs. Marilyn Mosby publicly and with inciting rhetoric announced ata press conference that she had fled criminal charges against Casear Goodson, Garrett Mille, Edyard Nero, William Porter, Brian Scott Rice and Alicia White', all "ide taste il charges, difeeat “Bron Rice and a iret “Alicia Whit,” who never ha any interaction with Me: Gray and ae not enforcement ofc, were msakenly charge wit crimes cling manslghey, 1enployees wih the Baltimore City Police Department. These charges included second degree ‘murder, manslaughter, assault, misconduct in office, and fas imprisonment? The charges were based upon events which occurred on April 12,2015. In unprecedented det, the State's Attorney read word for word the Statement of Probable Cause tothe public, Near the conclusion of her ‘ress conference, Mrs, Mosby herself directed a “message” to the world: “To the people of Baltimore andthe demonstrators across America, heard your cll for ‘no justice no peace’ Your peace is sincerely needed as I work o deliver justice onbebalfof his young man... [To the youth ‘ofthe city. wil sek justice on your behalf. This isa moment. This is your moment. Let's insure ‘we have peaceful and productive rallies that will develop structural and systemic changes for _Eeneatons to come. You're atthe forefront ofthis cause and as young people, our time is now. ‘This was not the first nor only statement revealing the State's Attomey’s political and personal motivation, betraying the United States Constitution, the Maryland Declaration of Rights and the ‘Maryland Rules of Professional Responsibility? ‘The 14 Amendment to the U.S. Constitution guarantees all citizens protection from overzealous prosecution, stating in relevant pat, “No sate shall. deprive any person of life 1ibety, of property, without due process of law." The Maryland Declaration of Rights, Ar. 24 also states clearly, “{tJhat no man ought to be taken or imprisoned or disseized of his freehold, ‘sau false ares, end miscondot in office, Bete Defendant Brian Scott Rice ad Ais White eed ‘homie in be arent wares fr hr Bren Wesley Rice andthe focorect Mis. Alia White were ntact The enor ia the delifation was om th charging documents prepared byte ShenifPs Department end adopted by the State's Atom in er press coneeoce. This war nt alec enor, bt rate nought eor by those who rere responuible for elarglng the Defendants "Garett Miler nd Edwaed Nero were chard with second degree asa, fle imprisons and misconduct in office. Wiliam Pre and Alita Who wer both charged with manslaughter, secon depee asa nd ‘maconduct in fee. Brinn Scot Rie was charged wih manelaughter, second degre san misconduct i office, td fae imprisonment. Case Goodson is charged wih second degre depraved Hert murder, anslaaghir, Second degre xs, and misconduct in office 5S, "Tbe people of Baiore City elecied me asthe State's Atomey to apy justice fit and eau to ola! epeat offenders and individuals who go and wp the authority a pie ocr" Inerviw with Don emoa, CNN (May 1, 2015).liberties or privileges, or outlawed, or exiled, or, in any manner, destroyed, or deprived of his life, liberty or property, but by the judgment of his peers, or by the Law ofthe land.” This constitutional ‘overlay has been influential in developing further guidelines and rules of professional conduct for prosecutors and other atforneys. The Maryland Rules of Professional Conduct outline the manner bby which sttomays must porport themselves in the egal arena. Specifically there are special rules regarding the manner by which prosecutors must conduct themselves and rules governing conflicts coftnterest! In Maryland, we hold prosecutors to a higher standard fora reason ~an individual's ‘constitutional sights hang inthe balance and the prosecutor must uphold those rights, even in the face of political and personal pressures, For the reasons discussed below, each ofthese principles outlined above have been egregiously violstod by the State's Attomey for Baltimore City Rarely in the history of any criminal ease has a prosecutor so directly maintained so many conflicts of interest, Rarer still are instances where such clear conflicts exists and a prosecutor steadfastly refuses to recuse him or herself’ These conflicts include the following: (1) the seizing ‘of politcal and personal gain by Mrs. Mosby and her husband; (2) personal relationships with individuals who will be witnesses a trial; (3) the role of her office asthe “investigators” for this case; (4) the pending civil claim against Mrs. Mosby and her office; and (5) the financial interest of the attorney for the family of Freddie Gray, a close fiend, financial supporter and attorney for Mas. Mosby. ‘There is no better evidence demonstrating these conflicts than the charging documents themselves. At best, the charges levied agninst these officers are extraordinary prosecutorial overreaching. At worst, they are something far more nefarious. 4 See, e: MD. B. C15 J. AND ATTYS Rule 16812, MRPC 1.7,36,3.8 Se In esponso ta question aso her response ta reqest at se ecess hal, Mis. Mosby responded, ar” Tnerview with Doa Lemon, CNN (Mey 1, 2015. 3‘The conflicts presented by the State's Attomey's Office are doep, are real, and are imminent. ‘This motion is being filed at this junction because the Defendants have grave concems about the charging decisions which will be made inthe near future and thir ability to receive due process ofthe law. Before ths case proceeds further, the Defendants would respectfully request this Honorable Court to recuse the State's Attomey and either dismiss the case, such that an independent prosecutor, appointed by the court can make any further charging decisions, or appoint an independent prosecutor to decide how the case should proceed. FACTS ‘The salient facts of this Motion will be set forth in further detail inthe Argument section ofthis Motion, However, a brief overview of the facts surrounding this incident is necessary to set the appropriste stage. (On May 1, 2015, a Major from the Baltimore City Sheriff's Department signed, underoath, an Applicaton for Statement of Charges against each of the above-referenced individuals. The charges ranged from second degree murder to a myriad of misdemeanor offenses, The charges all, relate to the alleged apprehension of Freddie Gray on April 12,2015. Itis apparently the position of the State's Attomey’s Ofice thatthe original investigating officers lacked probable cause to arrest Mr. Gray, asthe knife for which he was arested was “lawful under Maryland law.” (See “Attached Exhibit 1, Statement of Probable Cause against Garrett Miller; itis believed that this Statement is identical for each of the Defendants). No allegation of force was alleged in the ‘charging documents. tis not the position or averment of the State that any police officer beat Mr. Gray, or used excessive force upon him. Rather, itis simply the postion of the State's Attorney ‘thatthe original arest was unlawful, asthe knife was “lawful under Maryland law” (emphasisadded) and thatthe ensuing events ({.e, not seat belting Mr. Gray and not providing him with ‘medical assistance) flowed from the unlawful acest, OF significance to this Motion, there ‘was one individual inthe back ofthe van with Mr, Gray dving a portion ofthe events, Donta Alten, Unfortunately forthe Stale Mr. Gray wasnt erected and charged with violating Maryland law. Rather, Officer Garrett Mille rested and charged Mr. Gray with violating Section 19.59.22 of the Baltimore City Code. It should be noted that the City Code is far broader in its prohibitions than Maryland law. This pivotal distinction was omited from the Statement of Charges sworn out by the Sherf’s Department. This distinction was similarly ited from the Statement of Probable Cause rea to the cameras by Mrs, Mosby. Iin fc, the aie was unlawful or one was reasonable in abedit that it was, the foundation ofthe Sates argument collapses. If the knife was actully legit stands to reason thatthe very people who charged these Ofiers would then be guily of false imprisonment of each ofthe OfficerDefendant, by vite ofthe logic employed inthe Site's charging decisions. It should be noted that counsel for Defendants Miller and Nero (the two officers with pending District Court tril dates) have requested to see the actual knife on multiple occasions. Each ofthese requests have been denied. (On May 7, 2015, a Notice of Tort Clsim was filed with the Mayor and City Counsel of Baltimore and the tate of Maryland, placing the City and Staten notice that the above-referenced officers intend fo purse «claim against Mrs. Mosby and those responsible fr charging his ase 1s the charging documents contain errors and omissions that resulted in the unlawful arest and ‘Ste blde fives (8) Poseson or alee, probit. I sal be unlawful fr any person Sl cay, of possess ay knife wih a astm pring ooter device fr opening andlor lowing the blade, commonly kno [es snitch bade kif (0) Any peron vesting th provisions of thir ection sal upon convistion href, be Fined ot mre than $500 or be imprisoned for not more thn I yea, or bo nh iereton othe cour” BALTIMORE, MD, CODE a 19, 5.27; Se Atached Exhibit 2, Satemet of Chars for Fede Gry. 5Aetention ofall six of the offices. (See Attached Exhibit 3, Tort Claim & Public Information Act Request) ‘Mrs. Mosby publically contends that the charges were levied against these Police Officers after a thorough and independent investigation conducted by her offive. It is the position ofthe Defendants thatthe charges against them are baseless and that there are material false statements and omissions contained in the Statement of Charges. Mrs. Mosby's office performed the investigation, and as such, the employees and agents of her office have become the central witnesses to this case ‘As discussed in detail below, the chief prosecutor ofthis ease isin a relationship with a local television news reporter, That reported conducted an “exclusive” interview with Donta Allen ‘on May 1, 2015. The story that Mr, Allen told this reporter is key to the defense ofthis case and is substantively different in certain respects ffom the story that he told the original police investigators, a5 detailed in a search warrant executed earlier in the iavestigation of this matter. ‘As such, the reporter is also a witness to this case. ‘As further discussed below, Mrs, Mosby's husband is a councilman forthe very district where these events occurred; her inciting rhetoric in this case reveal clear extra-prosecutorial motivations and ambitions. Finally, Mrs. Mosby's personal and professional relationships with the Gray family attomey, William Murphy, cast a shadow over the prosecution and all charging decisions. As discussed in detail below, Mr. Murphy is not only a mentor and financial supporter of Mrs. Mosby, Dut, also her attorney. It should be noted that yesterday, in a separate and unrelated matter to this one, a similar Motion to Recuse Mrs. Mosby ftom Prosecution was filed on the grounds that her relationship‘with William Murphy unfily biased the outoome and status ofthat case. I was alleged in thet “Motion tht two Defendants both also police offices) were charged with identical erininal charges based on identical facts It was alleged that onthe day Mrs. Mosby was swom into office, she entered a nolle prosequ (dismissal) agunst Mr. Murphy's client. A eopy ofthat Motion is altace as ie Each of these conflicts, separately and individually, as well asthe statements made by Mrs. ‘Mosby tothe publi in her capacity as the State's Attorney for Baltimore City, demand recusal, ARGUMENT [A State's Attorney's “decision to prosecute, just lke the methods [s}he employs to procure ‘conviction, must be in accord with the fair and impartial administration of justice, untainted by ‘any contatninating influence.” Sinclair v. State, 278 Md. 243, 260 (Ma. 1976). The Sinclair court further stated, “if « prosecutor has, or would clearly appear to a reasonable person having ‘knowledge of the pertinent facts to have, any pecuniary interest or a significant personal interest ina civil matter which may impair [her] obligation ina criminal matter to act impartially toward both the State and the accused, then [she i, on the basis ofthis State's public policy, disqualified {rom initiating or participating inthe prosecution of that criminal cause.” 1d at 254 “The Sinclair Court went onto hold thatthe following reasoning was apt ‘The principle long ago was recognized that no man can adequately, ‘or properly serve two masters, and this is the chief subject matter of Canon 6 [(now Canon 5) ofthe Canons of Professional Ethics. tis inconsistent with the public interest and welfare for any law ‘enforcement officer directly or indirectly to represent any person. involved in a criminal matter, except the State, or receive any personal profit or gnin as the result of the arrest, conviction ot acquital of one charged with the infraction of the Jaw or in ‘connection with the filing of any such charge. . . . The books are replete with cases indicating that any appearance of evil in ‘connection with the administration of public office should and must,be avoided; and particularly is this tre of those offices involved in the enforcement ofthe aw. ‘To permit a prosecuting attomey to have an interest of any nature whatsoever in any civil proceedings, direcly or indirectly, and Which proceedings involve similar facts or the same subject matter 1a criminal prosecution then pending or thereat initiated, can ‘only give rise to suspicion concerning and relating to the motives of the prosecuting attomey involved, and bring such office into disrepute with the public. Id, at 255-256 citing State v, Detroit Motors, 62 N.J. Super. 386, 163 A. 24.227, 229-31 (L. Div. 1960), Maryland has also statutorily addressed the inherent need for prosecutors to be held to higher standards, Section (a) of Rule 3.8, Special Responsibilities ofa Prosecutor, indicates that ‘prosecutor ina criminal case shall “refrain from prosecuting a charge thatthe prosecutor knows isnot supported by probable cause.” Further, section (c) states in relevant part thatthe prosecutor shall “refrain from making extrajudicial comments that have a substantia likelihood of heightening public condemnation ofthe accused.” These special responsibilities of a prosecutor ae in addition to Rule 3.6, which applics to all atorneys in the context of trial publicity, Section (@) of Rule 3.6 states, {a} lawyer who is participating or has participated in the ‘investigation or litigation of a matter shall not make an extrajudicial statement thatthe lawyer knows or reasonably should know will be disseminated by means of public communication and will have & substantial likelihood of materially prejudicing an adjudicative proceeding inthe mater Both the spirit and law of Sinclair as well as the statutory rules outlined above have been egregiously violated by the Baltimore City State’s Attomey’s Office, As such, this Honorable Court showld grant this Joint Motion to Dismiss and, in the Altemative, for Recusal of theBaltimore City State's Attomey’s Office in the prosecution of each ofthe Defendants’ respective 1. THE RELATIONSHIP BETWEEN MARILYN MOSBY AND NICK MOSBY CAUSES AN UNAVOIDABLE CONFLICT. Standard 3-1.3(0 ofthe ABA General Standards forthe Prosection Function identify the basis forthe Defendants assertion that Mrs. Marilyn Mosby/s relationship to Mr. Nick Mosby, and the respective roles thatthe payin the pottical community of Baltimore City, establishes a basis for Mrs, Mosby (and the Office of the States Attomey for Baltimore City) to be disqualified fom prosecuting the cases ofthe above-referenced defendants, officers ofthe Baltimore City Police Department Standard 3-1,3 (0) Conflicts of Interests states: “A prosecutor should not permit her professional judgment or obligations be affected by his or her own politcal, financial busines, property or personal interests,” “Marilyn Mosby, State's Attorney for Baltimore City, is married to Nick Mosby, Councilman for the 7 District of the Baltimore City Council. Mr. Mosby's distict includes many of the neighborhoods effected by the civil unrest and rioting that occured inthe City of Baltimore after the death of Freddie Gray. A review of the Baltimore City Council Webpage, and specifically, a review ofthe 7 District Communities’ chat are geographically locsted within the confines ofthe ‘Council Distt, discloses tat the Committees and Associations tht are in that District include: Mondawnin Merchants Association Mondawmin Neighborhood Improvement Association, Inc Nehemiah Homeowner's Association of Sandtown-Winchester Pena-North Nehemiah Homeowners’ Association Penn-North Revitalization Corporation Pennsylvania Avenue Merchants Association * See Attached Exhibit 5, Map of the Cy of Baltinore 7 Couns Distt and a lisig ofthe DistPennsylvania Avenve Redevelopment Collaborative Sandtown- Habitat Homeowners' Association Sandiown-Winchester Community Building in Partnership Sandtown-Winchester Improvement Association ‘Undersigned counsel believes that this Court can take judicial notice ofthe fact that the neighbochoods set forth above were harshly impacted and considered "Ground Zero" for the ‘violent turbulence that took place after the death of Freddie Gray. The images of these communities ere projected in every local and national media form and medium that covered the violence that emptied in Baltimore City. All communities that are within te confines ofthe 7 District are home to the constituents of Mr, Mosby, He clearly had a professional and personal interest in the need to climinate the rioting and destruction ofthe property in his Council District. Likewise his wite, Marilyn Mosby, bad a professional and personal interest in accommodating the needs of her husband - his politcal foture directly affects her personal, professional end political interests “The need to quell the raging infemo of human rage and revulsion within the confines of the 7 District was emergent. Failure to put an end tothe destruction of property and the ongoing violence would lead to greater degradation of a community that had existing systemic problems ‘within the community. Me, Mashy’s relationship with the State's Attomey for Baltimore City placed him in a unique position to influence the decision of an elected official who was susceptible to be influenced in choosing to file criminal charges against the defendants in this matter, It is inconceivable that Mis. Mosby was not influenced by the chellenges presented to her husband as ‘ community leader of neighborhoods that were literally "up in tlames.” “The preservation of prosecutorial impartiality is perhaps most important during the charging process, the phase of a criminal proceeding when the prosecutor's discretion is most apparent. The theme which runs throughout the criminal procedure process in this country, and in this State, is that all persons should be protected from having to defend against frivolous 0prosecutions and that one major safeguard against such prosecutions isthe function ofthe State's ‘Attomey in sereening criminal cases prior to instituting prosecution, Surely, an essential aspect of this safeguard must be the prosecutors freedom from any personal or emotional involvement in a controversy which might bias her objective exercise of judgment. Chants of "no justice, no peace, no racist police” were heard throughout the stoct of Baltimore before (and aftcr) Mrs. Mosby elected to hastily announce that she determined that it ‘was appropriate to charge the above-referenced defendants with criminal acts Soon afer a Major ofthe Baltimore City Sheifs Office appeared befor a District Court ‘of Maryland Commissioner secking the issuance of arest warrants fr the six officers who are the defendans in this matter, Mis. Mosby Reld a press conference. AL this press conference Mis “Mosby proclaimed that she brought cxsninal charges against the officers to show not only the people of Baltimore, but als “the demonstrators across America that "heard your call fr ‘no justice, no peace" and proceeded to move forward with the politically motivated prosecution of the six officers who have served the City of Baltimore as proud polie officers. Asa result, these offices son found themselves offered upto the masses by Mas. Mosby to quel! the uprising that ‘caused the most harm tothe District where her husband is the City Council representative. The National Distict Attomeys Association National Prosecution Standards offers ‘uidance to prosecutors inthe execution oftheir dues. In he iatrodution othe Standard, tis sated tha, “These standards are intended tobe an aspirational guide to professional conduct in the perforntance of profesional function. Unless otherwise indicated, they are intended to apply to the chief prosecutor (by whatever tile) in any office, as well as to deputy and assistant prosecutors.” n‘Standard 1-3.3(@) appears to be somewhat similar tothe ABA Standard, but offers stronger Tanguage in encouraging a prosecutor to recuse himself or herself from involvement in @ matter that may have the appearance of conflict of interest. Specifically, the Standard states, “The prosecutor should excuse himself or hersef from any investigation, prosecution, or other matter where personal interests of the prosecutor would cause a fair-minded, objective observer to conclude thatthe prosecutors neutrality, judgment or ability to administer the law in an objective ‘manner may be compromised.” ‘The language used by the National Association of District Attomeys in offering guidance o prosecutors in regard to determining when it is appropriste to remove oneself from the prosecutor function as it relates to an investigation or prosecution that may be influenced by & personal matter is clear, and direct. Any fair-minded, objective observer would conclude that Ms. “Mosby's neutrality, judgment and ability to administer the law in an objective manner was, and is, ‘compromised by her relationship to Nick Mosby, and his position as a. District Councilman. ‘Ms. Mosby must recognize this conflict, and make the ethically appropriate decision in regard to the conflict caused by her mariage to 7 Distiet Councilman Nick Mosby. She must remove herself and her office ffom the prosecution of this matter. U1, _ THE BALTIMORE STATE'S ATTORNEY'S OFFICE SHOULD BE RECUSED BECAUSE OF PERSONAL RELATIONSHIPS BETWEEN A KEY PROSECUTOR IN THEIR OFFICE AND AN INDIVIDUAL WHO WILL BE A WITNESS AT TRIAL. Counsel for Defendants demand that Mrs. Mosby recuse herselt and her Office trom the above-captioned cases in light ofthe inherent and overly prejudicial conflict raised by the lead prosecutor's relationship toa potentially vital witness who is also a key member of the local media. Jan Bledsoe, Esq,, Deputy State’s Attomey and lead prosecutor forthe State, is in a relationship 2‘with Jayne Mille, an investigative reporter for WBAL-TV. This relationship was confirmed by ‘Tayne Miller tothe Baltimore Sun, as recently as Friday, May 1, 2015, (On April 27, 2015, a search warrant was executed on the home of Officer Caeser Goodson. According to the affidavit attached the search warrant, Donta Allen, the only other person inthe ‘back of the van with Mr. Gray during the ide, indicated Ww Inmicide detectives on the day of Mr Gray’s arest that, in his opinion, “Mr. Gray was trying to hurt himself” (See Attached Exhibit 6, Search Warrant), (On April 29, 2015 the Washington Post reported that a second passenger was in the van “with Freddie Gray and according toa source the passenger heard Gray “banging against the walls” of the van and described what he believed was Gray “intentionally eying to injure himself.” The Post article referenced the Search Warrant but omitted Mr. Allen's name, citing eoncems over his safety? ‘On April 30, 2015, Jayne Miller of WBAL presented an exclusive interview with the second passenger, Donta Allen. When interviewed by Jayne Miller of WBAL, the individual who vas in the van with Mr. Gray somewhat retracted his earlier statement. He now stated that he heard “Tight banging” and that he “never ever said to police that [Gray] was hurting himselE.” Dring this interview with Ms, Mille, Allen described a barier which divided the rea ofthe van {nto two sections and as such, Allen stated that not only did he not see Gray, or realize there was ‘a second passenger, but that “there's no place where a man can hurt himself in there.” ‘After Jayne Miller's interview with Donta Allen, itbecame clear that Mr. Allen's story had changed. Accordingly, Ms. Miller necessarily becomes either a substantive witness or an After M.A interview with ayn Miler, the Washington Post digo ono rele is ame, 2impeachment relative tothe veracity and detsi of Mr, Allen's story. Theis simply no way around this confit Itis unclear how Jayne Miller of WBAL leamed the identity ofthe otherwise anonymous passenger. However, the fat remains that Ms. Miller interviewed Mr. Allen prior to Ms. Mosby and Ms, Bledsoe fing xi orto the results ofthe police al Larges pis the defendants and investigation being fumed over to the Stie's Atomey's Office, That interview, therefore, presumably wes considered inthe decision by the State's Attorcy's Office to ave charges filed. ‘The conflict is traly problematic in that Mr, Allen presented a difeeit version of events that is more beneficial to the State's theory ofthe case in speaking with Ms. Miller. Thus, Defendants ‘would have an opportunity to examine Ms, Miller as to the nature of her conversations with Mr. ‘Alten prior to his interview, any statements he sid while not being recorded, and any statements he made as to why he had varying accounts of key testimony in the ease. Ms. Miller may also need to testify sto the authenticity ofthe recording of Mr, Allen. Ms, Miller and er notes eve already been requested and subpoenaed by Defense counsel In further recognition ofthe inherent confit, on May 5, 2015, Jayne Miller stated, “I'm cally going tobe covering less ofthe Freddie Gray case, because Ihave a personal connection toone ofthe prosecutors” Couns! for Defendants avers that his confit has erated the ned for the parties involved thus far to recuse themselves. As others, inch 1 Jayne Miller herself have ecopnized tis confit of interests and recused herself, Mis. Mosby should els recognize this undisputed conflict and recuse herself from any further prosecution i the above-captioned eases. “This conflict seal and undeniably intertwined withthe prosecution and charging decisions ofthis MI, THE BALTIMORE CITY STATE'S ATTORNEY'S OFFICE SHOULD BE RECUSED BECAUSE OF THE STATE'S ATTORNEY'S OFFICE'S “INDEPENDENT INVESTIGATION, DISREGARDING THE BALTIMORE POLICE DEPARTMENT INVESTIGATION. ‘The conflicts with Mrs. Mosby's office extend well beyond the conflict of her chief prosecutor and a witness. The conflicts involve the entirety of he investigation andthe necessity of calling all “investigators” as witnesses, Mes, Mosby has publicly stated that the Baltimore Slate's Atlomey’s Office has conducted its own independent investigation, under her supervision, apart from the Baltimore City Police Department investigation. Specifically, she has stated in her ‘press conference held on May 1, 2015, “1 thought it was very important to have an independent analysis as to what took place and transpired from the very beginning. We are independent agencies from the police department, We've been ‘working independently. And I can tell you that we put all of our resources to make sue that we were pursuing and leading where the facts took usin this case, which was to pursue justice. Ican tell you that from day one, we independently investigated. We're not just relying solely upon what we were given ftom the police department, period.” In an interview following the press conference, Mrs. Mosby publicly addressed the investigation further stating, “can tell you, a8 I stated, we had a number of investigators. You ‘ean see it's been an allchands-on approach from the very beginning. So, I sent my investigators out tothe scene. We have a ‘umber of them who are right here... So, yes, we have leveraged the police investigation, but at no point did we compromise our own independent investigation into this case.” (emphasis added) ‘Mrs, Mosby's statements are telling in that she repeatedly refers to and implies thatthe investigators essigned by the Baltimore State's Attomey’s office are under her control. She refers to them possessively because they are her subordinates and subject to her supervision and ‘management. 1s‘The fact that these investigators sre controlled by Mrs, Mosby creates a clear and undeniable conflict of interest. These investigators will necessarily be called to testify as result ofthe defendants right to attack the investigation conducted by the Baltimore State's Attomey's Office. As Mrs. Mosby is ina supervisory role, these investigator witnesses ae at her mercy in ‘erns oF Ur weil enploynca slaus. As Lely, hese witnesses cannot possibly be expected to tetity without unde influence. They undoubtedly know that thei testimony may be central to the til strategy and clear noodof their employer to biain a convietionof the defendant. As such, their testimony willbe unduly influenced by a desire to maintain employment withthe Baltimore City State's Atomey’s Office. ‘When the State's Atlomey assumes the role ofthe investigator, her office becomes the witness, In order to appropriately defend this case, the defense will be required to attack the investigation, as it was erroneous, egregious, and deeply flawed. This attack will necessarily require subpoenaing and calling as witnesses many of Mrs. Mosby's employees. Itcannot be ssid that this does not presenta confit of interest with her office. This is precisely the reason for separation of the police department and State's Attomey's Office. Here, the State's Attomey Office ha erated an indisputable conflict, simultancously taking on therole of police, prosecutor, and witness IV. THE BALTIMORE CITY STATE'S ATTORNEY'S OFFICE SHOULD BE RECUSED BECAUSE STATE'S ATTORNEY MOSBY HAS A DIRECT FINANCIAL AND PROFESSIONAL INTREST IN THE OUTCOME OF THE As (On May 7, 2015, a Tort jms Notice was served upon both the City of Baltimore and the State of Maryland alleging that false and misleading statements and omissions inthe Statement of ce offices Probable Cause resulted in the unlawful arrest and detention of each of the six po involved inthis mater. It was alleged in the Tort Claims Notice that, amongst various other issues, 16the legality ofthe knife and the law under which Mr. Gray was charged, were falsely detailed in the Statement of Probable Cause. As a result the Tort Claim’s Notice states that Mrs. Mosby and her office “do not now have any legally justifiable reason to believe thatthe above-referenced individuals had committed the crimes for which they re charged” (See Attached Exhibit 3, Tort (Claims Notice). The Tort Claims Notice yoes on to aver Ut if it ft the hie at issue was illegal (as indicated by Officer Miller in his charging document of Mr. Gray), then not only is there an absolute defense t these criminal cases, bu, there is claim for false imprisonment, arrest and malicious prosecution of the six police officers, resting squarely on the door step ofthe State’s Attomey's Office. As discussed below, because of the State's Attomey Office's investigatory role in this matter, they have forfeited immunity from ivi suit. “Moreover, The Baltimore Cty State's Attorney's reckless, careless and inaccurate public stalements are not protected by absolute immunity and have thus exposed her to civil liability and potential discipline by the Attomey Grievance Commission of Maryland, creating an impermissible personal bias and necessitating the appointment of an independent prosecutor. Despite clear guidance from the Court of Appeals discouraging public statements by a prosecutor Which may diminish a defendants right to an impartial jury and fair trial, Mrs. Mosby's inaccurate statements and inflammatory hyperbole at her press conference potentially subject her to sanction fiom the Attomey Grievance Commission and civil liability. See, eg, Attorney Grievance ‘Commission of Maryland v. Gansler,377 Mi, 646 (2003). Choosing to ignore long established Supreme Court Case law regarding the diminished immunity of a prosecutor who acts as an investigator and gives extrajudicial statements, Mrs. Mosby has subjected herself to civil suit by the officers she secks to prosecute. ‘The threat of ”‘pecuniary and professional sanction have stripped Mrs. Mosby of the impartiality necessary to fairly make prosecutorial decisions moving forward ‘The United States Supreme Court in Buckley », Fitesimmons gives clear direction that a prosecutor enjoys “absolute immunity for the initiation and pursuit of « criminal prosecution, ling pesentation of tho tte’ case a il” Ducky v. Fssinmons, 09 US, 259, 270 (1993). This absolute immunity includes “the professional evaluation ofthe evidence assembled by the police and appropriate preparation forts presentation at tial..” However, Mrs. Mosby has gone to great lengths to stress he decision to levy charges was based on her offices “independent investigation,” and not reliant on the Baltimore Police fon. Furthermore, Mrs. Mosby declared at her press conference that her office performed the role ofan “independent investigntion.” The Cour in Buckley, relying on its decision in Imblerv, Pachonan, 424 U.S. 409,432 (1916), retrates that prosecutor who act as an investigator and not as an advocate doesnot enjoy absolute immunity Furthermore the comments have violated Maryland's Rules of Professional Conduct, Rules 3.6 and 3.8 (Special Responsibilities of a Prosecutor) which require attomeys to reffain from making extrajudicial statements that have “a substantial likelihood of maesially prejudicng an adjudicate proceeding” and probit a prosecutor fom filing charge not supported by probable cause, Mrs, Mosby's public assertions at her press conference fly in the face of the Court of [Appeals stem warning to prosecutors that “a prosecutors, in particular should be even more ‘cutious to avoid making potentially prejudicial extrajudicial statements.” Gansler at 698. ‘THE BALTIMORE STATE'S ATTORNEY'S OFFICE SHOULD BE RECUSED BECAUSE OF THE COMPELLING INTERESTS OF THE ATTORNEY FOR THE FAMILY OF FREDDIE GRAY, A CLOSE FRIEND, FINANCIAL SUPPORTER AND ATTORNEY FOR MRS. MOSBY. 8tis the position ofthe undersigned counsel that Mrs. Mosby, andthe Office of the State’s ‘Attorney for Baltimore City, be recused from further prosocution ofthe named Defendants in the ahove cited case numbers. There is an overwhelming conflict of interest that has arisen, and continues, in the State's Attorney's representation of the City of Baltimore. Mrs. Mosby has a guile personal wel profesional ielaioahip with Wilians H. “Dilly” Murphy the founding partner of Murphy, Faleon & Murphy. This ongoing relationship has created a confit for which the only remedy isthe reeusal of Ms. Mosby and the Baltimore State's Attomey’s Office, Mr. Murphy is the Gray family atomey and presents himself as their confidant nd spokesperson, He has repeatedly appeared on television, both locally and nationally, on behalf of the Gray family, Mr, Morphy has a substantial financial interest in the outcome of any criminel case against these six police officers, as any guilty finding will improve his positon in any potential civil suit against the City of Baltimore and its police department. With reference to any potential civil claim by Gray fuily for whom Me. Murphy is counsel, ifthe death of Me. Gray was found to be scidentl and in the couse ofa legal detention, at best 2 claim under Maryland State law claim for negligence or gross negligence would be supportable. As a result ofthe Local Goverment Tort Claims Act and Maryland tort law, there ‘would be a limitation of les! goverment lity, and Me. Murphy would notable to rsover attomey’s fees. Tat cap in local government liability would not be applicable i the Gray faily hud a viable federal Consttatona claim under § 1983, and atomey's foes could be awarded to ‘Mc. Murphy, Notably the charges agnnst Ge Defendants that Mrs, Mosby most clearly overreached on are false imprisonment, assault, and second degree murder, each of which involve some level of intent, Intentional action under color of law wihich deprives and individual of @ 19Constitutional right allows for a Constitutional § 1983 claim, ‘Therefore, Mrs. Mosby's pursuit of criminal charges involving intent, potentially has dies financial impact on Me. Morphy. ‘Mrs. Mosby's connection to Mr, Murphy is of great concem othe undersigned counsel, and it shouldbe of even greater concer tothe residents of his ity. Ms. Mosby had Mr. Murphy has a member of her team as she began the process of trailing aloe sole as the State's ‘Attomey for Baltimore City. Me. Murphy also donate significantly to Mrs, Mosby's campaign, in essence helping her win her postion. The connection between Ms. Mosby and Mr. Murphy is undeniable and the conflict it cretes is detrimental in the pursuit of justice. “The Maryland Rules f Professional Conduct equie attomeysin all positions to adhere to 2 stiet code of ethical conduct. Mrs. Mosby's coated prosecution of the named Defendants ‘woefully underrepresents justice, which is at the core of any prosecution. Maryland Rule 1.7 specifically stats that there is a conflict if “her is a signicant sis tha the representation of one ‘ormore clients willbe materially limited bythe lawyer's responsibilities to another cient, former lien ora third person or by a personal interest of the lawyer” (emphasis added), In adition to her personal relationship, Ms, Mosby as a professional relationship with Mr. Murphy. A complaint was filed against Ms. Mosby to the Attomey Grievance Commission of Maryland lato last year. In an email dated October 29, 2014, Mr. Murphy outlines his representation of Ms. Mosby. (See Exhibit 7) It is elear from the exhibit, and from the response ofthe Attomey Grievance Commission of Maryland, that Mt. Murphy was tained by Ms. Mosby. "Not only was Mr. Morphy’s fm retained but he personally handled her matter. ILis unclear as to whether this professional relationship is sill ongoing with regards lo any subsequent lings. ‘When interviowod recently by CNN's Don Lemon, Mis. Mosby was asked about her contact with the Gray family. She indicated that she had brought them in to her office and “spoken 20With them and their tomy.” Mrs, Mosby has clearly had direct contact with Mr, Murphy in regards o this case ‘The Maryland Roles of Professional Conduct are very clear when it comes to confit of| interest. Its plainly stated in Comment 8 under Maryland Rue 1.7 that, “elven where there is no direct advorences, a onic of interostoxcaif thro i a ignfiont rie that a lawyer bility to consider, recommend oF cary out an appropriate course of action forthe client will be meteilly limited as result ofthe lawyers other responsibilities or interests." The Court can glean guidance fiom Comment 26 of Rule 1.7, which states tha, “relevant factors in determining whether there is a significant potential for material imitation include the duration and intimacy ofthe lawyer's relationship with the client or client involved, the functions being performed by the layer, the ikethood that disagreements wll arise and the likely prejudice tothe client rom the conflict." ‘Yesterday, in a separate and unrelated mater to tis one State of Maryland v,Jeftey Bolger, a nearly identical Motion fo Recuse Ms. Mosby ftom Prosecution was filed on the grounds that her relationship with William Murphy unfsirty biased the outcome and status ofthat cas. It ‘was alleged in that Motion that two Defendants (bth police offers) wore charged with nealy {identical criminal charges based on identical facts. It was alleged that the two defense attomeys (Mt. Murphy and Steve Levin) had hoon roqueting the State's Atomey's Office, prior to Me Mosby taking office, to dismis all charges as they were not supported by any expert opinions (to the contrary the medical examiner's report actually supported dismissal of Mr. Levin's lent, not ‘Mr. Murphy's). According tothe Motion, on Mrs. Mosby's fist official day after being sworn into office, she entered a nole prosequi (dismissal) in favor Me. Murphy's client. See Attached Exhibit, Motion, State v.Bolger). ‘The Motion cites the unftir and undeniable intertwined nrelationship by Mrs, Mosby and Mr. Murpay, The same reasoning applies with even greater force to the instant case CONCLUSION Each of the above-captioned Defendants have fundamental concems about undeniable ‘coullicts of interest which have turned the prosecution of this case into a platform for oxtra- ‘prosecutorial motivations. These concems are rooted in the United States Constitution, the ‘Maryland Declaration of Rights, the Meryland Rules of Professional Conduct and the ABA’s ‘Guidelines for Prosecutors. As stated earlier, these concerns are deep are real and are imminent. ‘They require a dismissal ofthese cases, with he ability of an independent prosecutor to re-evaluate the charging decisions, or, in the least « recusal of Mrs. Mosby's office. Respectfully submitted, Mtl B. rang? Sean Malone Harts Jones & Malone, LLC 2423 Maryland Avenue, Suite 100, Baltimore, Maryland 21218 (410) 366-1500 Attorney for Offteer Caesar Goodson Meer Zonwgeos © Mare. Zayon Roland Walker & Mate L:Zayon,P.A. 201 N. Charles Stet, Suite 1700 Balimore, Maryland 21201 (aio) 7.3710 torn) for Ofc Béward Nero Catherine FI Mead, Flynn & Gray, P.A. (One North Charles Street, Suite 2470 Baltimore, Maryland 21201 (410) 727-6400 Auiorney for Officer Garrett Miller Heat fteatle * Murtha, Pores, & Lanasa, LLC 1301 York RA, Suite 200 Lutherville, Md 21093 (410) 583-6969 Attorney for Officer William Porter 2bo M Elet © Whe Bey Chaz. Ball Scblachman, Belsky & Weiner, P.A. 300 Bast Lombard Street, Suite 1100 Baltimore, Maryland 21202 (410) 683-2022 Attorneys for Lieutenant Brian Rice 2 SRA © ivan Bates Tony Garcia 201 N. Charles Street, Suite 1900 Baltimore, Maryland 21201, (410) 814-4600 Autrey for Sergeant Alicia WhiteCERTIFICATE OF SERVI U HEREBY CERTIFY that on this 8 day of May, 2015, a copy of Defendants? Joint Motion to Dismiss or Inthe Alternative Recusal of Baltimore City State's Attorney's Office was sent via first-class mail, with exhibits, postage prepaid, to Janice Bledsoe, Deputy State's Attorney, Office of the State's Attorney for Baltimore City, 120 ast Baltimore Stret, ! Moor Baltimore, Maryland 21202, dal | e— cm L de fA | if} — Mifiael Belsky Ma Bates 4STATE OF MARYLAND * INTHE * pisrricr couRT + FOR * BALTIMORE CITY CAESAR GOODSON + CASENO. spo2294452 GARRETT MILLER + CASENO. sBa2204449 EDWARD NERO + CASENO, 4B0z204450 WILLIAM PORTER + CASENO. oBoz204453 BRIAN RICE + CASENO, 2Baz204448 ALICA WHITE + CASENO, sba2204451 Defendants : Defendants request a hearing on their Defendants’ Joint Motion to Dismiss or Inthe Alternative Recusal of Baltimore City State's Attorney's Office. a Gatferine Flynn roa te fueRs [A om [t— 4a [A Micha Belsky Tran Boles 2s‘STATE OF MARYLAND + INTHE * — pistricr courr "FOR * BALTIMORE CITY CABSAR Goonson + CASENO, cno22o4ss2 GARRETT MILLER + CASE NO, spozz94469 EDWARD NERO + CASE NO, apaz2944s0 WILLIAM PORTER + CASENO, ono2294453 BRIAN RICE. + CASENO, 2no2204448 ALICA WHITE, * CASBNNO. sH02294451 Defendants . ORDER ishereby ORDERED on this__day of. thatthe Defendant's Motion to Dismiss or i the Alternat Attomey’s Oltice is HEREBY GRANTED, ‘o Recuse the Baltimore City State's JudgeDISTRICT COURT OF MARYLAND FOR Baltimore City Lect 5800 Wats Aven, ior, ind 2115 Case No. 302294449 ‘STATE OF MARYLAND VS." MILLER, GARRETT EDWARD. a ye Phone ‘come | State | Ast Charge | site est ASSAALT.SEC DEOREE Jo 9208 agsauursceoreare jon aes | teeconauer Norncd (ai?! eiSconobr RSeree Ta. FACS PSONMENT TOL ARREST WARRANT ON CHARGING DOCUMENT - Warrant No. D150291702 Ra ea —— YOU ARE ORDERED to arrest ap tid before judicial officer the above-named Defendant as soon as Practicable and without necessiy dels, Ia judi officer is ol realy avilable, tis Ware shel ‘authorize the prisone?s detention until éomplane shad with Rule 4212 andthe eres offices uthovised and required to comply with Rae 4212 Mf THE DEFENDANT IS NOT IN CUSTODY FOR ANOTHER OFFENSE, Initia sppearane if be hed in county ia which Warant was saved i i banENDAs Ith CusvOar FON SNRTER SS 6 Warne bene | deren oe NeTREEINE Yara oe ae a a | ‘efor a judicial fice ofthe Diniet Cou / i Dale: 050172015 Tine:02:31 AM. JudpComaoed IIs Rarsrarv Given: BALTIMORE CITY SHERIEF'S DEPT RETURN OF SERVICE CrGority tow at free pm on_shehes “uC Sprrmat Bookings 4 _ exe his Aves Waray resin te Deen sadn iy aie tag af Te etna Cre asopya te Warn and GPa a ees orth cote detonate Defeat a espn Ceca. tSpeimte Location: Abi i Signature & Tie of Pete OMT Printed Name of Of Agency, Sb-Agoney, LD: EXHIBIT, Date _ h } ‘Tracking No:_ 181001323896 § ARREST WARRANT ON CHARGING DOCUMENT DartsAN DISTRICT COURT OF MARYLAND FOR Baltimore City enaaeae eee _—}__* "ae STATEMENT OF CHARGES UPON THE FACTS CONTAINED IN THE APPLICATION OF MAJOR, SAM COGEN IT'I$ FORMALLY CHARGED THAT MILLER, GARRETT EDWARD at the dies, times and lotions specified below: NUM CHOICIT STATUTE PENALTY DESCRIPTION OF THE CHARGE nee aben ou2015-ou.annis ih NR FREDDIE CARLOS GRAY, J, in te end dee ‘tin fH .03, entry te en of be nara ech LAY. , + Stent nd proved wean pa, greed es a *. Mrs Kai the ace, Govermen nd igi ote Sie oo sis naa wyasebasond ASSAULTS DecaKE On EE avaois AUG oibatocK oF Nene Sacer BALTIMORE MARYLAND isa FREDDIE CARLOS GRAY. J, i te sod dep elon 25, oye om fe state em om 20668 cn ’ sasconouer otic Foo. OF PReShun SIRT BALIINORE MARYLAND THAT GARRETT EDWARD MILLER. A PUBLIC OFFICER, WHILE ActIngUNDEA Colon ar gore. commun Dib | [REQUIRED BY THE DUTIES OF HIS OFFICE AND CORRUPTLY DID A. | fave Acton VoL ation Ti CowaON LAW OF ‘Asai Fee, rene an Die Sins, oe 2065 eu wlsconpuctw ornce Ttsn00Beocx oF Moun STREET TAT owAneersoWwARD cen a vue uence, ws seth oom coon or gon coanry Sib [REQUIRED Ay Te DUTIES OF Hs OPE AND CORKOPTLY DIO A ‘ene Pe, Gave a Diy ote Se ‘Ono About D220 5 "doo Rao BLOCK OF Date: 0811/2018 Time : 09:31 AM isomer! SY. Martin (318 isis ‘Tracking No, 151001323896 bens‘CONTINUATION PAGE 1 OF STATEMENT OF CHARGES DISTRICT COURT OF MARYLAND FOR Baltimore City Loci a S800 Wabash Aves, Balimore, Maryané 21215 Cave No, 32294049 STATE OF MARYLAND VS. MILLER, GARRETT EDWARD cra i ly an moral eM, FRED CARLOS GRAY, ‘ite Pes ovement, Nebeodt. Maiti 5 Date : 051012015 Time: 09:31 AM Judit Otic 15 ste ‘Tracking No, 151001323896DISTRICT COURT OF MARYLAND FOR _ Baber Cly, Wabash Ae, ee IEattmore. Mo 21215-8530 © Casa No soezo4ee9 ‘Cope. Ya. Sm, = 00 NCalver Stet sen Balle, MD 2 410-396 1155, Sremmepeg rae. AN SS, Buin iy Shr One e073 DEFENDANTS DESCRIPTION aI; ——e oir. Byes. Corleone —_. a APPLICATION FOR STATEMENT OF CHARGES 1, the undersigned pply for statement of charges and summons or warat which may lea othe aes he above named Defendant because on of bout APLI2.2015 _ (See Below) 7 + the sbove area Defiant yee “Se spe Ba 18 a esa aoa ‘ofthe Hana Pls rata HAPS We a ul SiR DRSGY CARN BAT We, cae rede Carls Gray. (008 816198). Having made eye conte, Mr, Gray sbscguesy en 1 Rigs, Rice then digi oer adpartmeatal ido dt be was volved ina fon puri which pe ke “zal Offices Miler and Nezo slg began fo pee Me. Gay, (cote) (Comins on ataced res) DOCK Ta) | eaten ais under the pele of pray th he conta hie plc are rc to the best of my knowledge, Information and bli - May 12015 : ~ en Tavera adm nd ie Ni ii ay uans - srg gem gents LAE ot a ‘Te M oe ‘understand tat charging docomest wil be suds hat most appear for wil) on : igs tonene Llwhen slid bythe Cl the Ova natn slarnn wap oP am GE RE YS tneve avd appa of sing sght Aplin etn sili a eh ie IE herring document ese i of probe b ; rearssoorazsnes © over ex 2206) ° iDISTRICT COURT OF MARYLAND FoR Bslimare Cl, Wabash AVE, tyro) 1c ave Ne: suozzecea | sin Bator, wo 21296-2590 ier, Garrett Edward APPLICATION FOR STATEMENT OF CHARGES (CONTINUED) Page 2... of « Having.come in. contact with the pursuing officers, Mc. Gray surrendered to. Officers. Miller.and.Nero.(n.the.vicnity.ofthe.41700 black of Presbury. Skeet ono. Officers Miller. and. Nero. then handcuffed Mr..Gray.and.moved him.to a location a. few. feet away. from_his surrendering location, Mr-Gray.was then, placed. in.a prone position. with his,arms.handouffed behind his back. It was at this.time.that Mr. Gray. indicated. that he. could not breathe and requested an jnhalat.to.no.avail. Officers. Miller.and.Nero then. placed Mr. Gray in.a.seated position andu..aisusna subsequently found. a knife clipped to.the.inside.of his pants pocket. The biade of the. knife, was folded into the.handle, The knife was not a switchblade knife and is Jayful under. Maryland law.. These officers subsequently removed the knife, and. placed iton the sidewalk. Mr. Gray was then placed back down on his stomach, alwhich time Mr. Gray began to fail his legs, and scream as Officer Miller placed Mc. Gray in.a restraining technique known as.a "leg lace" while Officer Nero. physically held him down against his will unt a BPD wagon arrived to transport Mr. Gray. Lt, Rice, Officer Miller and Officer Nero failed to establish probable, cat Mr, Gray's arrest as.no crime had been committed by Mr. Gray, Accordingly, Lt. Rice, Officer Mille, and Officer Nero illegally arrested Mr, Gray Upon arrival of the transport wagon, driven by Oifice Officer Nero, and Officer Miller loaded Mr, Gray into, PD, wagon to stop at Baker Street, At Baker 9. Officer Nero and Officer Miller removed Mr. Gray from. the wagon, placed flex cuffs on his wrists, placed leg shackles on his ankles, and completed required paperwork, Otticor Miller, Offi oxic. “7ra#951001329098 | PE DCICR 1A ev. 2) ‘courT coPYDISTRICT COURT OF MARYLAND FOR Salinere CW. Wabash AVE. cure APPLICATION FOR STATEMENT OF CHARGES (CONTINUED) Page. of 5. loaded. Mr. Gray_back into.the. wagon, placing him.on.his. stomach, head first onto {he-fleor.of the wagon..Onee. again, Mr. Gray.was not secured by.a seatbelt in the .wagon..contrary.t0.a BPD. General Order. Lt. Rice. then directed Officer. Goodson {9 transport Mr. Gray.to the. Central Booking and Intake Facil, _ Following transpert.from Baker Street, Mr, Gray suffered a severe and orilical ‘eck Injury. as.a result of belng handcuffed, shackled by his feet. and... unrestrained inside.of the BPD wagon...From Baker. Street, Officer, Goodson broceeded to the vicinily.of Mosher Street.and Fremont Avenue, where he... Subsequently parked the wagon and proceeded to the back of the wagon in. ord fogbserve Mr. Gray. Despite stopping.for the purpose of checking on Mr, Gray's, condition, at no point did he seek, nor did he render, any medical assistance for Mr..Gray...Offcer Goodson relumed to his driver's seat and proceeded toward nttal Booking and intake Facility, with Mr, Gray still unsecured by aseat belt, contrary to.a BPD. General Order . Several blocks later, Officer Goodson. check on the status of his pflsoner and request Street ang ll Avenue. Officer William Polphin Street and Druid Hill Avenue. Both ,Goodson al proceeded to the back of the wagon to check on the status of Mr. Gray's Gray requested “help* and indicated that he could not breallie, ‘asked Mr. Gray ifhe needed a medic, at which time, Mr. Gi indicated at least twice that he was ir physioally assisted Mr. Gray from despite Mr. Gray's appeal for a oster uf, | Tepers1001923606, ‘court cory PCDOICR 1A (tev 12)DISTRICT COURT OF MARYLAND FOR Satine Cy, WBE AYaciomn ‘ote Ns: ozaaaes nl iy MD 212163990 ler, Garett Edward APPLICATION FOR STATEMENT OF CHARGES (CONTINUED) Page-4....0f © oneiition. and at.no. point id elther of them restrain Mr. Gray, pet BPD General Order, nor.did. they. render.or request medical assistance... ~ While discussing the transportation.of Mr. Gray.for. medical attention, a request. for additional units. was. made for an arrest at. 1600, W. North. Avenue. Officer. Porter left the vicinty.of Dolphin Street.and Druid Hill Avenue,to assist in.the arrest of another. prisoner at North Avenue, Despite Mr. Gray's. obvious and recognized need for medical assistance, Officer. Goodson, in a grossly negligent manner chose to respond to the 1600 block of W. North Avenue, with Mr. Gray. stil unsecured by a, seat belt in the wagon,, without rendering to or summonsing medical assistance for Mr. Gray smi Officer Goodson arrived at North Avenue to transpx vidual arrested at the location of North and Pennsylvania Avenues, at which time he was again met by Officers. Nero; Miller, Porter, and Lt. Rige. Once the wagon arrived, Of ‘Goodson walked to the back of the wagon and again opened the doors fo wagon to, make observations of Mr. Gray. Sat. Alicia White, Officer Porter, and Officer Goodson observed Mr. Gray unresponsive on the floor of the, wagon, Sat. ‘White, who was responsibie for investigating two citizen complaints pertaining to. Mr. Gray's illegal arrest, spoke fo the back of Mr. Gray's head, When he did not respond, she dd nothing futher despite the fat that she was adi Besplto Mr Grays seriously delererating medioal condition ‘no medical assistance was rendered to, or summonsed for Wr. ey at that time by any officer... ‘ys 191001320800 PC DCIER 1A (Re. 18) ‘court corySCAT ED A COURT ADORE 800 Wabash Av Balt, MD 21215, fparoare noe cast rast fille, Garett Bird APPLICATION FOR STATEMENT OF CHARGES (CONTINUED) rge 5 [ne be woes caving Mr. rey, GF Undine proceed oth Wess Dia Polls Sans whos Int toe BPD Gencal Order, he gan edi retina Me. Gray nto wage oe cane ee At he Wenem Dit Flic Shion the detent reset Neth Avene metros seed at ured isd ofthe rolex santo tending Mr Gra. By te ee Oe Zac Now Sp, Wits stood to emore Gay fo the watn Mr. Go wan lng onting wat Ame ee ae ons San Gee Hes reasons | Decnnia tec eunisIMPORTANT NOTICE ‘The attached papers charge you with committing s crime. Depending on te erime charged, & jail sentence could be imposed by the Court if you are foun! guilty. You should be represented ata trial by alawyer, ACTIMMEDIATELY to contact the Publie Defender orto hire private counsel. Ifyou do not have the money to hie private counsel, you should contat the OFFICE OF THE PUBLIC DEFENDER immeditely. Ifyou wait o acrange for a Pubic Defender or private counsel, you can be made o stand wil without a lawyer. You may contact any Public Defender office including: : * si00 WABASH AVENUE, BALTIMORE, MARYLAND 21215 “oS g10-978.8114 [ PUBLIC DEFENDER TOLL FREE NUMBER FOR ASSISTAN 877-430-8187] ‘The following papers re required 1 obtain Public Defender Services 1, Court charging documents/Traffic tickets, (Statement of ChargesAll documents issued to you by Court, 2. Thal date notices from the Cour: (Contact the Public Defender as soon as possible even ifyou have not received a trial date notice.) 3, Lfyoware employed: Proof of current income i the foem of slay or paystubs forthe last wo pay periods 4, Ifyou ae unemployed, Proof of publi assistance} radical assistance, AFDC, Socal Seewity or Supplemental Secuity Inedme (SSD, or other assstnee you are receiving. ‘The Office ofthe Public Defender is open weekdays ffom 8:30 ni 04:30 pan, Cll immediately o find out when and how you can make your application, RECEIPT ‘Thave read or have had r08d 1 me, the contents ofthe shove notice and acknowledge receipt of copy thereo. IF YOU DO NOT HAVE A-LAWVER ON THE TRIAL DA’ HAVE TO GO TO TRIAL WITHOUT THE ASSISTANCE OF A LAWYER,Fygzraaon usc PIRI Selatan yu enna tee td Sacer > Stanmore rrp nt sd pcan cas aac ae te orga nee fet pater areatimetate ett Ginagienestae eater eee am Sse eee ate 3 Setar remot seer marae Simi ier Fpecragie CRITE nt any amet i es ter retires ch cncrn tart eat a gene terete hl legate ote orice Se Sriealeareerrenen ee cane pmecepereai hat aetna np neem Sohtatne taco aman cece oes sea soimsearivantess NOTICE TO DEFENDANT. |. MUST APPEAR Ife wih yu ne cnae sa MUST APPEAR alee, yu my Wb ee ope tes en tnd PLEASE NOTE TAT FALRETO APPEAR AY RESULT BEA WARKANTPOR YOUR AROS 2 PRESET FINE= Yume yt a, sey sae ann ae meta Note ies con. ily ncn on sin CHARGED BY STATEMENT OF CHARGES SUMMONS OR ‘Wana, cituck Ove OFT FOLLOWING OPTIONS SGN AND DATE, AND MAL THIS POR, LONG WI & ory on tie STATEMENT OF CHARGHSGUNMONS ON WARKANTTO Tt ADDRESS SHOWN HELO Cornoxm: yt leon of ret fl a my Dist Cot My ean oh ocr the Maye ain We oy one Gn be) yma ethene sau blo Tony mal {te rsh. my oni tes Cour a ryan. Ine cain mabe yo wo yon h, | Anion 10 sere elle nga fret ire, a on Reqs Waive Hey aici non nh Smet Cage and rete «miner apn he ‘tests toed undsun saa tl fee and whe wi at ese dy eens et i er See on Regi il et et i he fr Be lain) hg. —— a tres Cour Trae Provaung Cet ‘iste Coert of Marylee imap MD 360.4676 Pies tht jy nil oft re wl see ian sd heey of sevice th an Paseo ae "ht pin wi based by Motor Vic Aten (VA) on your ving erate encore Wolo of Be Mer Veil Lt ‘fl Sat tye iio amply wit ent be aoe epions ihin 30 afr cala/sumeonaran, MVA wl oie et ‘nye wos ped ours Diving co ped esa ater for wl you cube news TOK MORE INFORMATION AND TO PAY CITATIONS ‘isn Mb dary Wee xsd ends he nese Vo Repose VR) Sem rl nes, ‘ots nd dso. pa From ll ses incon a fui i002. 2686 ‘THY wer ea velo RELAYS ZI "have ad erhoe tin edo mete cone he lps ad towels rei of op ttt, De acer) Dee Teles Connisinerar04sas007 Comtar* 23572 cicurr court oR DISTRICT COURT OF MARYLAND FOR BALTIMORE CITY “Tore Hoveabie Jas (9) —— ofthe). athe undenignee ‘rng dy swova depos wid a athe) Rs) tess TROVE ut onthe preniag inthe Cty oftatinore this now eng conte ei property, ney, (2 limes Plc naruto, dpartnent nud lang erst deptimestah ‘a pots nts and Mack wrk shoe or oa TEER Go) viene relating the commision of ce perth ()_inesta deh rpoetnd nde Daluore City Compaen nae spate AND ta thefts ending to esablsh sounds fori of Seach Warren are efor the Av © atacand ade a tee! WHERETORS your hfloa(o pn) ‘hata Stash and Sere Want be need rd Sworniobetoce mend mbsritedoinmy pesencethis aay of 20k AAA DISTRICT COURT OF MARYLAND FOR Baltimore City ‘oca t S00 Wabath Avene, Baltinore Magand 21215 Case No, 6802294074 ‘STATE OF MARYLAND VS. GREY, FREDDIE CARLOS JR STOR ELMLEY AVE. COMPLAINANT: a LS AVE MILLER, G OFC ATOR 201 2a was st BALTIMORE, MD 21211 Sp sores Bu Race) SEM eSB" Wes Hic BLX Eye ORN DOB:ONNESES! Phone Poon) STATEMENT OF CHARGES TON THE FACTS CONTAINED IN THE APPLICATION OF MILLER, G OFC IT'IS FORMALLY CHARGED THAT GREY, FREDDIE CARLOS JR atthe des, tmes und lnctieas ested bles NUM cholo sraTuT PENALTY DESCRIPTION OF THE CHARGE on 95900 yaessonee wire BLADE naves 0 narabat i205 Troi enesouny sr ALTIMORE Mo aval cry, roses, na aco known sich ‘dh its orate ng er rds geod ay ‘ais te ina of ano ap * a ‘Agente Fee ovens nt Dig of be Se Date : O4/122018 Time: 11:25 PM ‘Tracking No, 151001271606DISTRICT COURT OF My .¥LAND FOR _ | Berinpanrspescumor nave Lieses E =GO0~261~ 02-640 sex 0A. nese wT! yn E> © ti BUC tyes Grsata Complexion oer. —— oa Gc f24_ APPLICATION FOR STATEMENT OF CHARGES Fa tof _ 5, thewnderigned, app fe satement of charges aa sume OF wat which may lead othe ape othe ovemmet Dena bene oor abn nf 2005 wa! Blas ol tery Balin MO QD SE Ateod no the, fad os z Sra recoured/ (Cominued on ances Pag) (DICK 1A) ‘lenny ffm ud the pestis of peru thal th one fis Appleation se tus othe best of ny knowlege, information and belie "iver ord mse te Neola om Apel ors er Sutsrited and sworntobeireme this LPH. gy op ARP PEM ety Te MSC A alpine. yee ip J underst fot op lien nd tate git on ZBL - ot Se Bes RN "Ten ona by te Ur he Cot leon sown ihe eo is oom S500 Cagaty a ~ ive advised applicant of shielding right. PR Applicant declines shielding, ‘D1 detned ossue a charging document because of lack of probable cause, us ce Qe DBCICR (er. 122006) Pan Dae (e209DISTRICT COURT OFM._YLAND FoR. [oocares ar eouRr ADRES er Ne [bnnaNis ya naar FST re Sr, Freckle. Cocks APPLICATION FOR STATEMENT OF CHARGES (CONTINUED) Page_ by hes cfhce= ol Pantha gas, asenk a chisel ported fevbe, ta —— lt Apel Jor i “Savor ] DCICRIA(Rev, 17002) Pv Da ava014 coi er |MRS. Sail Aeroaneve a0 Lair www MasionanaeCoo.con May 7,2015 VIA HAND DELIVERY AND CERTIFIED MAIL WITH RETURN RECEIPT REQUESTED, George A. Nilson, Esquire Baltimore City Solicitor BALTIMORE C1Ty LAW DEPARIMENT City Hall, Room 31 100 North Holiday Street Baltimore, Maryland 21202 VIA HAND DELIVERY AND CERTIFIED MAIL WITH RETURN RECEIPT REQUFSTED. ‘The Honorable Nancy K.Kopp, Treasurer Louis K. GoLbsTeIN TREASURY BUILDING 80 Calvert Steet, Room 109 Annapolis, Maryland 21401 Re. TORT CLAIM & PUBLIC INFORMATION ACT REQUEST Claimant ‘Bdwaed Nero and Garrett Mller ‘Agency/Agencies: Mayor & City Council of Baltimore, Maryland, State's Attorney's Office of Baltimore City, Baltimore City Sheriff's Department & the State of Maryland ‘Date of Incident(s)-_May 1.2015 to Present and Continuing ‘Dear Mz, Nilson and Ms. Kopp: ‘Our firm represents Edward Nero and Garrett Miller in all clsims against () the Mayor & City Council of Baltimore, Maryland and its agencies, and their agents, servants, and employees; (il) the State's Attomey’s Office of Baltimore City and its agents, servants and employees; (ji) the Baltimore City Sheriff's Deparment and its fagents, servants and employees; and (3) the State of Maryland and its agencies, and their, agents, servants, and employees (collectively, the “Governmental Eattis”), arising out of charges filed against them on May 1, 2015 (the “Occurrence”), These charges resulted in the arrest and detention of each of the above-teferenced individuals. The myriad of charges levied against the above-referenced individuals include false imprisonment, 2°° degree assault, and misconduct in office. These charges, and the charging documents in EXHIBIT H 3 ‘Wastrnoron, DC Orie» Kreme, NW Sons» Wassoncten DC sab FL 20859870‘Tort Claims Letter May 7, 2015 Page? support of them, were not and are nat supported by probable cause or arguable probable cause. ‘These claims include, but are not limited to, al claims falling under Maryland Code Annotated, Courts & Judicial Proceedings, §§ 5-301 et seq. (the “Local Government Tort Claims Act”) and Maryland Code Annotated, State Government, §§ 12- 101 ef seq. (he “Maryland Tort Claims Act”), This letter serves to saisfy the requirements ofthese statutory provisions. ‘The State's Attomey's Office af Baltimore City ("SAO") and its employees acluding but not limited to Ms. Marilyn Mosty) involved in the investigation, who by the SAO's admission took an investigative role inthis matter, as well asthe Baltimore ity Sheriff's Department and its employees involved in the investigation, each did not ‘on May 1, 2015 and do not now have any legally justifiable reason to believe that the above-roferenced individuals had cornmitted the crimes for which they are charged. In point of fact, many ofthe fats contained in the Statement of Probable Cause not only fail {o establish probable cause, but are patently false. Relative to each of the above-referenced individuals, charges were brought ‘against them including false imprisonment, 2" degree assault and misconduct in ofice ‘based in parton the legal argument that they arrested and detained Freddie Gray without probable cause. The charges state that the knife, which was the basis of Freddie Gray's ‘arrest, was lege and therefore no probable cause existed to arrest him. [Fin fact the knife ‘was illegal, as the above-referenced individuals contend that it was, then the underlying ‘acts that form the basis of the Statement of Charges against the police officers would be false. Accordingly, the charging documents, the arest and detention of the above- referenced officers would itself lack in probable cause. ‘The SAO and the Baltimore City Sheriff's Department are hereby put on notice that they, infact, akin tothe same logic invoked by the charging documents against the police officers, would themselves be osponsible forthe false imprisonment and assault ofthe above-referenced individuals (eot to mention false ares) As aresult of the Occurrence, the above-referenced individuals lost ther freedom, and dignity and suffered physical and psychological harm from being arested, detained, {imprisoned and assaulted without cause. ‘The above-referenced individuals’ claims identified herein relate to wrongftl conduct engaged in by the Governmental Entities at the time of the Occurrence, with legal damages accruing as of that time and continuing thereafter. ‘One of the central purposes of this letter isto make a formal settlement demand ‘This setlement demand is made without prejudice to the above-referenced individuals’ rights, should settlement not occur, and no stetements contained herein may be used in Sitigation including as evidence) or for any other purpose, The stelements and representations in ths letter constitete an offer in compromise of ligation and none of‘Tort Claims Letter May 7;2015 aged the information contained herein is to be considered or construed as an admission of any kind. If e settlement is not reached, my clients reserve the right to claim the tae and fal value ofthis matter at tial As a result of the injuries and damages sustained by the above-referenced individuals from the Occurrence and continuing thereafter, they each demand a sum in ‘excess of $75,000.00, plus interest costs, and all other relief deemed necessary and just ‘under the circumstances. This demand is made against all Goveramental Entities, jointly and severally. ‘Marvland Public Information Act Request ‘This letter is also a request for all information, records, and documents, related to the Occurrence in the possession of the Govemmental Entities, as required by Maryland Code Annotated, State Government, §§ 10-611 er seg. (the “Maryland Public Information Act”) [fall or any part of this request is denied, you should provide a written statement of the grounds for the denial. If you determine that some portions of the requested records are exempt from disclosure, please provide the portions tha ean be distlosed. Please also note that certified copies of some ofall of the records sought are requested, Therefore, please advise as (0 the cost if any, for obtaining a copy ofthe records and the taal cst, if uy, forall the records described above before providing any teeords. If you have adopted 4 fee schedule for obtaining copies of records and other rules or regulations implementing the Act, please send me a copy. Preservation of Fvidence Including by this lt, the Governmental Entities are hereby given notice not estoy, concedl, of alter any paper or clectoni files and other data generated by andor stored onthe Governmental Enis” computers and storage media or ay other electronic data including any and all email and phone texting records relating to the identified subject area(s) ofthis comespondence. AS you may know, the Governmental Ents? failure to comply with a preservation notice can rel in severe sanctions boing imposed by a cout fr spoision of evidence o potenti] evidence. Should you have any questions, please do not hesitate to contact me. We look forward to your response. Vs yours, & fee { //The Law Offices of Joseph |. Tiwvis, Jr,p.a. jstiigaacom Pha sIO-727103 ON Chas Set Feal0s760091 Se 215 Balin, Myre 21201 ‘May 7,2015 | VIA HAND DELIVERY AND CERTIFIED MAIL WITH RETURN RECEIPT REQUESTED George A. Nilson, Esquire Baltimore City Solicitor BALTIMORE CIry LAW DePARTMENT City Hall, Room 31 100 North Holliday Street Baltimore, Maryland 21202 VIA HAND DELIVERY AND CERTIFIED MAIL WITH RETURN RECEIPT REQUESTED. ‘The Honorable Nancy K. Kopp, Treasurer Louis K, GoLDstein TREASURY BUILDING 80 Calvert Street, Room 109 Annapolis, Maryland 21401 Re, TORT CLAIM & PUBLIC INFORMATION ACT REQUEST Claimants: Alicia White, Casear Goodson, Brian Scot Rice and William Porter Ageney/Agencies: Mayor & City Council of Baltimore, Maryland, ‘ State's Atlomey's Office of Baltimore City, Baltimore City Sherf?'s Department & the Ste of Maryland ate of Incidents): May 1, 2015 to Present and Continuing Doar Mr. Nilson and Ms. Kopp: (Our fim represents Alicia White, Casear Goodson, Brian Scott Rice and William Porter in all claims against () the Mayor & City Council of Baltimore, Maryland and its ‘agencies, and their agents, servants, and employees; (i) the State's Attomey’s Office of Baltimore City and its agents, servants and employees; (i) the Baltimore City Sherif?'s Department and its agents, servants and employees; and (v) the State of Maryland and its agencies, and theit agents, servants, and employees (collectively, the “Govemmental Entities”), arising out of charges filed against them on May 1, 2015 (the “Occurrence”) ‘These charges resulted in the arest and detention of each of the above-referenced‘Tort Claims Letter May 7,.2015 Page 2 individuals, The myriad of charges levied against the above-referenced individuals include murder, manslaughter, assault, false imprisonment and misconduct in office. ‘These charges, and the charging documents in support of them, were not and are not supported by probable cause or arguable probable eause. ‘These claims include, but are not limited to, all claims falling under Maryland Code Annotated, Courts & Judicial Proceedings, §§ 5-301 et seq. (the “Local Government Tort Claims Act”) and Maryland Code Annotated, State Government, §§ 12- 101 e¢ seq. (the “Maryland Tort Claims Act”). This leticr scevea to aatiafy the ‘requirements of these statutory provisions. ‘The State's Attorney's Office of Baltimore City (“SAO”) and its employees (Gneluding but not limited to Ms. Marilyn Mosby) involved inthe investigation, who by the SAO's admission took an investigative role mn this matter, as well asthe Baltimore City Sheriff's Department and its employees involved inthe investigation, each did not ‘on May 1, 2015 and do not now have any legally justifiable reason to believe that the above-referenced individuals had committed the crimes for which they are charged. In point of fact, many ofthe facts contained inthe Statement of Probable Cause not onl fail toestabish probable cause, but are patently false. Relative to each of the above-referenced individual, charges were brought ‘aginst them including murder, manslaughter, assault, false imprisonment and ‘misconduct in office based in parton the legal argument that they aested and detained Freddie Gray without probable cause. The charges sate that the knife, which was the brsis of Freddie Gray's arrest, was legal and therefore no probable cause existed to arrest ‘him, If in fact the knife was illegal, asthe above-referenced individuals contend that it ‘was, then the underlying fats that form the basis ofthe Statement of Charges aginst the police officers would be false. This isan example ofthe false statements andlor other ‘deficiencies contained in the charges. Accordingly, the charging documents, the arrest and detention ofthe above-referenced officers would itself lack in probable cause. ‘The SAO and the Baltimore City Sheriff's Department are hereby put on notice that they, in fact, akin tothe same logic invoked by the charging documents against the police officers, would themselves be responsible forthe false imprisonment and assault of the above-referenced individuals (not to mention false arrest. ‘Asa result of the Occurrence, the above-referenced individuals lost ther freedom and dignity and suffered physical and psychological harm from being arrested, detained, imprisoned and assaulted without cause. ‘The above-referenced individuals’ claims identified herein relate to wrongful conduct engaged in by the Govemmental Entities atthe time of the Occurrence, with legal damages accruing as of tat time and continuing thereafe, ‘One of the cental purposes of this letter isto make’ formal settlement demand. ‘This settlement demand is made without prejudice to the above-referenced individuals’Tort Claims Letter May 7, 2015 Page3 rights, should settlement not occur, and no statements contained herein may be used in litigation Gncluding as evidence) or for any other purpose. The statements and representations in this letter constitute an offer in compromise of litigation and none of the information contained herein isto be considered or construed as an admission of any kind. If settlement is not reached, my clients reserve the right to claim the true and fall value of this matter at tial. ‘As a result of the injuries and damages sustained by the above-referenced individuals from the Occurence and continuing thereafter, they each demand a sum in excess of $75,000.00, plus interest costs, and all other rele deemed necessary and just ‘under the circumstances. This demand is made against all Governmental Entities, jointly and severally ‘Maryland Public Information Act Request ‘This letter is also request forall information, records, and documents, related to the Occurrence in the possession ofthe Governmental Entities, as required by Maryland Code Annotated, State Government, §§ 10-611 et seg. (the “Maryland Public Information Act") fall or any part ofthis request is denied, you should provide a written statement of the grounds for the denial. If you determine that some portions of the requested records are exempt from disclosure, please provide the portions that canbe disclosed. Please also note that certified copies of some or all of the records sought are requested. Therefore, please advise as to the cost, if any, for obiaining a copy of the records and the total cost, if any, forall the records deseribed above before providing any records. If you have adopted a fee schedule for obtaining copies of records and other rules or regulations implementing the Act, please send me a copy. Preservation of Evidence Including by ths letter, the Governmental Entities are hereby given notice not to destroy, conceal, or alter any paper or electronic files and other data generated by andior stored on the Governmental Entities’ computers and storage media or any othe elector ata, inckuding any and all email and phone texting reoorde relating to the identifod ‘subject area(s) of this correspondence. As you may know, the Governmental Entities’ failure to comply witha preservation notie can result in severe sanctions being imposed by a court for spoliation of evidence or potential evidence. Should you have any question, please do not hesitate to contact me, We look forward to your response, |‘Tort Claims Letter May 7, 2015 Page 4INTHE CIRCUTT COURT FOR BALTIMORE CITY? CEIVED STATEORMARYIAND + a HY=7 pH a2 . . ane No. ez Sf RE BI JEFFREY BOLGER * DEFENDANT'S MOTION TO DISQUALIFY THE BALTIMORE CITY ‘STATE'S ATTORNEY AND APPOI ‘The Defendant, Poice Agent Jftey Bolger (ered) (Agent Bolgee, dhrough undersigned counsel respectily moves this Coast purnast to Article V of the Maryland Constitution, Maryland ste law, the Fifth and Fouteenth Amendments to the United Sates Consnton, and the Code of Profemional Responsbiliy of the American Bat Association to disqulify the Balimote City Sets Attomey. The newly elected State's Adorsey appeets to have engaged in toubling pattern of favorit and politically ‘motivated charying decisions. Asa result svod the coatouing pearance of proptity in dhe proseiton ofthis cae, which severely andinpropely undesines the public's ith 4 the criminal jontce sytem and wotks an injortice yp thie defendant his Conct should ‘old an evidentiary hensing to determine whesher the Baltimore Cty State's Attorney should be dingalifed und anew independent prosecutor eigned to determine whether charges ate sppropeite [RELEVANT FACTS ‘The facts of this cate have been set forth in Agent Bolge’s Motion to Distise (Chusgng Document, led September 11,2014, sd in Agent Bolye's Motion ta Tice foe Flue to Preserve Evidence, fled December 12, 244, which are incosported hein by ‘ference. Ta rom, his ease concerns the prosecation of «22 yeut veteran of the Balkmote Police Department for actions he took inthe performance of hie dies on June 14,201, in faesesponding to an incest in which «stay dog bad ites ad puncte the hand of 4 ‘eqnunt woman. Responding to the see, Ages Bol psn, then Buldimore Pace (Ofer Thomas Schmidt COffcr Schmid, placed the Iso of a dog pole wound the sony dogs nec and vessiedit for soficent te thatthe dog sanguted ioe and speared flew as it hy on the groom According to te aatpated textinony of Malady Chief Medel Huandne, a welt vtenary foresie pathologit, dhe dog "ly edo a esl of strangulation doe to Office Schmit’ we of the dog pole! At the tine, however, Agent Bolger cou aot be extn thatthe dog was esd. Conceedin pt for the prtonged suleing ofthe animal, Agent Bolger made aug incon tothe dog's aco ate. ‘The Ofc ofthe State's Atcmneyukinately Bid charges punt bow offer, Oo Jue 19,2015, Agent Bolger was theft oft be charged. One weck ats ca June 25 205, Office Schmid ws lo chargedin connection withthe death ofthe do, In ve conte, Agent Boge engaged undeignd coun and Officer Schmit engaged the ar ‘am of Map, Falcon & Murph. The foun pains of ht em is Wien H. “Bly” Macpiny,Je,a welinown shih vine sopportr ofthe caseat Sut’ Aone, Maya Moni. (Exh B). Once engngd cours for Agent Belge and Ofce Schmidt. ean advocning forthe Seto damit the chugs against thet coats. (Exh. This ‘sa publi on-going, snd tint, for Agent Belge unsucenfl effort heughout the second half of 2014, (Eth. D), The, ia November 2014 Ms. Moshy was cece Se’ -Atomey for Bakimore Gy, dfeng the incon. I the een, Bily Morphy bad ropported Ms. Mosby, and eoanal far Agent Rolgeeopported the ncatsbent. (Pah, B and \ The Chic Metical Examines expert opinion was provided to the St’ Actomey pie to ter isin of charges opin Off Schade 8). pee 2uh. E), Ms, Mosby was publly worn in to office on January 8, 2015. On her ft oficial ay asthe Sates Artomey, she deopped he charges sguint Oficer Schmit. ah Following the dismisal of Ofice Schmid’ case, Agent Boge again requested supevioty ‘review ofhis own cat, bu the charging decision stood eventhough tro expert bave ‘steal opined that Agent Bolger didnot kil the sey dog? “The creat of ihe pot wo weeks in Bakimote ate known arcu the wold and ae ‘eraialy known to this Honorable Cour, On Api 12,2015, Fede Guay was zest by ‘members ofthe Balimoce Police Department. On Api 19, 2015, acconding othe figs ‘of Maspand’s Chit Metical Examiner, Me. Gy dette of njries surined dng bis area, Inthe days following his dest, peaceful protests begat take place in ana ‘sound Balisore. Baton Monday, May 4, 2015, the day Me. Gay ws to be ed to rest “the city wet up in moke” Bah. G), "That evening, Mayor Stephanie Rewlngy-Blake saounced dats iywide night curfew would be inpoted stating Tuesday from 10 pm, 05 asm, to semin in effect for one week. 1d. Col Willam Palen ofthe Mayland State Police announced thi wo 5,000 aw enforcement offile would be requested fom the ni-Adaoti region to help qullthe violence in Bainore, Id. Governor Hogan ‘sbeequeaty signed an Executive Order and clad in the National Guard. 1d. Schools were slosed. 1d, The Balimore Orioles payed the Sst jor league baseball pein history to ‘x empty stadium. Aad the miy of Freddie Gray engaged Bly Masphy to repeesen them. ah.» ‘cing the week of sting and vislent protest om Monday, May 4 dhrough Friday, ‘May 8, 2015, public attention became focused on Thatdiy, May 7, 8 pvr, bonne on that day the Bakimore Police Depatmen deleted the report oft invention to the £ OF cours even if Agent Bolger’ actions had caused the death ofthe dog, such actions did ‘not amount to einina conduet.Siate's Atomne for Bakimore Ci. The fct tha the repost would be submited, however, id not necessarily mean tit the police investigation hd conched. And in at it was 20 ‘On May 2, 2015, the Bakimore Sun epoted that it had been given excusive sees to the ‘BaldznorePotice Department’ Investigation whl it wis undet way, (Exh, H). On Frida, [May 8, 2015, Mosby aamouned her decison oehitge the ofices. But the ‘Balimote San reported this carne «complete suprise tothe police: ‘They had not expected the wate’ storeys office to act 0 6000. ‘Later on Friday, Mosby sid the charges were the rest of provecutors working 12-and 14-hour days alone police {nvestigaton She alo sid protestors had been working on & “parle invetigtion” chat included using cy thei depais. “This was uot something hat was quick ft and in a hu," she sd “We reviewed hundteds of hour of eaten footage and satement ‘Thisis something we worked relly hard to get tothe botom of” Sal, pleaty of tems remained onthe police tek force's checkin ‘Members Soon were back othe ievestigation- 1d The police were not he nly net who wet shoched. Public sentiment wa det. Bot seat tine, oly the plc new dat thee were substan unarwered question in the invenignion.Specsstion began to mount that Mt. Mosby wns impropety aGuence by ea thce hing: ex ean with Bly Murphy, he Gray iy aoeey the pable cutey cling for the prosecution ofthe ole, which ndudd song snd violent tet ander aban poli ake the cave. (hI). Nik Mosby eepeesenis ‘Bakimore’s ™ Dstsctin the Bkimore City Count Jd. That dst incades Penn Noth sd Sendtown Winchester, two ofthe neghbothoods in which Fedde Gay wat aesed sod eansported and which served athe epicenter ofthe wed of vance and destction ‘in Babimore, (sb. J. Ths the fe of Mx, Moy to charge ihe ofices would have ‘est potent to harm Coundinan Mosby's political cree, goto mention bet own,LEGAL ARGUMENT ‘ SEE ee ees ne pine ands hearing to determin wether anlndpenlor eee ee coped The Court of Ape of Maa nop at atom sion ‘psec ot Bete meas hc employ wo prot covcion, mt he ints ‘the ding adiniseton fs, site yay contig nS Sit, 78248, 26,395.24, 478097." So You 50 Ma. App 584155519, The Cot ako cgi "tt he Cal of rasa "espns Caen 9 ups herve‘ be Apeane often Impomey. Hower wear do sw of esate uty opt he inept ink rym he plo ine Sin "Youth usin ata whether a enc poe oe hte elie om cases emplyig nye th ad previa weed om he dete | fon tinge, The Cont Appa aoe dhs mbes aio ag Septal rohing ht ueona te emanate Chan $85 5242499 0576 ot dn 6 NM 73,5247 24908 (te Ne Meo Coun OF Area teving Se Lai 108A 2, 502724160 192, thar teamanc ke ote peed cate pros pre dpaea rowing nol cs Thi onan ware on he bof ne ‘ener impo thee ge Ge nee at ‘ceo alee who ha eer eet he defi th une ce een ow he fame ese oul at upd ae pean dad xeup 63 Ohio Min. 1,409.24 1070 (Ohio Cons PASE) and compare Low. Siprir on, 14 Cab p38 67, 168 Cape. $7 (Dit. 1960." 1 552. ‘Te Cont of Apes dined to adept such arr, Instn, te Court held ‘tat “ueehing che pubic interstin prompt nd effective proncution of emia cases sezins tele important publ itret of conSdeace in he impataiy ofthe pesecton, ‘we conclude that poly ofthe mere appearance ofimpeoptay, such a exited bere, ses not mandate appintment of aseitant count fo the Sie Lin Sat, pr, 288 (Maat 85, 415.424 119, Instead, when it appecs ht forme defense counsels presently employed in th protest ofthe til court should make fag 810 ‘whether the formes defense count as nay ser pari in the peng proecition ands to whether he hes eve tothe poteculon ay information abmined Sm is ewe cent Wien. Sta, 250 Ma. 425, 434-439, 430.24 58, 594-596 (1981." td ae 554555. While the ats of his av ae not anaogoa o Yea the contig principe ere ‘he sume. Ifthe protection ofa cate nites the appentnceofmpropity,the const san obiigtion to determine whether thes in ct ny coroping induence IF there ia 0% the este ay proceed. Buti thre the poser’ ofc must be igual, The cians of amore must cersily hope tht Ms. Mosby acing in god ith 1 the dpaches bedi atthe Buliore City Sates Auocsey. But even giving Ms Mosby the benefit ofthe doub, she canna oid these ipa crested by these objcvely erable ats, Marans Chief Medial Busine opine that the dog Hkly ied asa esl of phintion dot the we ofthe dog ple, yet Ms Mosby rejected hit Pini in dsming the charges arnt only Ofer Schnit on hee fst officiel day in fe, 1a Me Gay's however, Me Moy ppacay seed wpa the fading of thisme medial examine: when making a charging dcion. (Exh K). Other question sil ets, De Me, Mosby have such hen intrest nse death of say and vicou dog that ‘he watenly made it pricy o eve the comprrtve mess ofthe ese aut the ‘ro charged plc offices and decile to dia justo of der one very ft dyin ofc? Cerny, he nine Asitant Stat’ Atomes who were responsible for Ofer Schmid’ cate bleed into they would have advocated fri sisal months eae. When Ms. Moby was ected did thove ansigedattoeneys havea change of ent and make ieee peony oly the newly lected Sat’ trey one fet dyin fc 50 Ofer Schmid cate cou be immediately emionted? Nea of these question i ly ‘0 besnrweced inthe aflsmative. The public could ely conch da the dbl o the cate apsinst Ofer Schmid at whos hands wo expen wil ef that he dog kel died tile being angulated onthe dog pls was a smal vor fora pls mentor. ‘The pbc wl hve to sort out own questions wth ep to what eff the ‘Stes Atoreysseltionship with he tome for he Gry fanly had on te haying Aessionn ia that ae, Bus longs hoe queson at being ted in the pub sqare, ‘he State's Attorney cannot atid the eppestance of inpopiny wih cg to he continuing prosecution of the cave spins Agen Bolg (ened on nxt phWHEREFORE, Agent Boies apectily request this Hononble Gout bold a ‘eng to dtemine whether proper, wade nthence affected the decom to dismiss he charges apis Offices Seid, while conning to prosecte Agent Bolger, ho was the Iuwenfrcemen fcr md eponsle fo the det ofthe stay og. In Cone s0 conden, Agent Bolg opel sects the ppisnens of xa indepedent psec. Respect obnted, ‘Sterea H, Leva. Saeah Facey LEVIN se CURLETTLLC OLN. Chasis Se, Suite 2000 Balisnore, Maryland 21201 Te a10.685-4048 ex 410.695.2022 ceulet@levincalett coma Abn fo ie Boge CERTIFICATE OF SERVICE 1 hereby cetfy that on this Teh day of May, 2015, the foregoing Motion to Disgoalify the Balimore City Sates Atomey and Appalat as ladependest Prosecutor was eivere via First Clas Mailto the State's Attorney for Baltic Cay. Lobaniilledf hacer N-Calet,JSerna, LEVIN &CURLETTuc ‘hate cadet Je ‘Bots Maiand ‘elena com December 12,2014 Vi Ema nd Fit Cl Mai Gregg Bete, Eaguite "Slaabeth Embry, Eoquire Paul O'Connor, Bagure State's Atoene’s Ofc for Balmore City 120 B Bama Set, 9 Noor Bakimore, Mayland 21202, Re: State of Maryland v Jelly Bolger, Cate No, 614227006 ‘Cacale Cow foe Baltimore City Dear Messrs. Bemstia and O'Connor and Ma Ease: ‘The defese hereby spplements ite previowsdiclonure concerning expert witnesses pursuant to Maryland Role 4.265) Dr. David Fomte, the Chief Medial Examines for the Ste of Maryland, wil testy that Police Agent Jeffey Bolger did noe kl dhe dog Nala when he made tines in Oe og’ neck with» kif. De: Fowler wil testify that the ime he incision wat ade, the og was szeady dead, having ely died by asphyxiation die to the use of the dog poe Ds. Fowler wil tify thatthe concasion of Ds. Nepoe ~ namely, tat the Ick of| blood in the heart snd the coloston of the spleen exuibish the dog's case of death os _esilng from the cut to the nee encoun, De Fowler wil testify that the ac of blood # the place of action, at evidenced by fhe photogrphs ofthe dog taken onthe 900 block of South Grancy Sect, demnonrtae thatthe dog's ear hid ateady stopped bentng tthe tine of the inion ‘For eam, ‘one edge ofthe ent line i devcid of blood, and theres no erence of ati tpay, De, Exe 1 ADecember 12,2014 Page 2 Fone wil testify that tis topos to conchde thatthe dog ded from ood loss when ‘the dog's head bad been removed prior to media extmiaation Is adation, De. Fowler will estify that the colomtion of the kidney, int a ‘tablishe that the dog did not de from blood lows. Dr. Fowke wil opine on rlevnt media cbeertions tht coatiute ts hi pectic opinions and the ove substance of his finding ‘You have charged Agent Bolger with ilegaly tiling a dog As you have scknowledged, under the State's theory ofthe ease, Agent Boles excaivly lable for his cows ctions, independent of the actions of the other aut, Therefore, 4 fet Gnd’ scceptunce of Dr. Fowke’ testimony would be fatl tothe Stc’s eae. In ght of thin oe invite you to conuet De. Fowler direct to dacs hi analy We believe that ones Yo tare done so, the State will be compelled to dismis ths casein advance of tn becuse it ‘cannot prove is case beyond a reasonable doube ‘Very ely yous, (Chases N. Cut,B Frogooutor ka io tn Grny , comes from police family | | ‘Teed pnd are —— | FeoOiEaRay Sctapimes sooner | ln om Uigreatenaver engineering shay ded ate fe Yen en tniertng | Sores a Utedentiaiaieng — Sacawitaninr non tece Soueneen, Sonne i {= ‘Wieren Brown, ¢retran Bakimore defense lyer wee | mea opemnet ad | dante eae sees a Moira” Sewers” | ia aut | | “ean aidbopnie i | TRENDING Now'N | a elie Oto bt series cancer ia eeeinai steht Rom he bis May ns imo Perec tenes ‘ot ioe sty bbe hay. ‘Tetkstratomceietomiae tte penwstiriatenry | Ha nants othe ont a iy leptons | ‘olentohr perp ar | ‘a pain sed hp probe ce cg | pga Dk Tee Mey pt iticotniee and tbr hts cacon wear | At renin Deact | ‘sy i st spf nb ly li bk yy ibys fer trot eet eek sce rey peda bee nhc ee en ‘tm ston ‘anton Serbo Ne Taped Uniey oon RECOMMENDED FOR YOU a | a = ed | ee togpart [ecrsiocoe | alofoatatnptatnna sete wneteur | mhempemediyaargtne |LEVIN&CURLETTic generis ante “simone a Oe Eras mt@evincabt. com, me” Seagrass sepnbe1,204 on 1. Bem = Set Amey Balas Cy a Elinor Sc hee ce Sous {inter ations cer ee Mie ba ounce Re: Shite of Maryan v.Jeffey Bolger, Case No. 614227006 ewe Me. Sut’ Attorney On Septaner 1,2014, we fed» moto o init caging dace oie ce bene oe ee ca a ane hi inthe abence of « pelininry hea, We now a you to seconsdet whether cae lage shold be bought aust Ages Belge ta. Agent Baber ss ene the Hakinoie Pace Deptt zd fone: member our ton aalag es ok ‘abemisedsecord of pubic serie in both pecs, Agee Belge? segs Mee tes afaly chanced the ei at hing beth andere for foro pote ae 8 the ent, hi ceive» gi nk ced ot eal ye Cer eh 4 mbes of the pues he soorn to do. Te een tat ee bea, “rcp ens lee og pay 1 Police Agent Bolger had been informed dat thesis dog he was called to confront ‘ad biten a haman being, 2 The hur being who wa ten was a prepnant wom; 3. The dog bite punctured the womaa’s hand: 4. The metic who responded to the scene informed Agent Boge ofthe eceny of ‘ataing thatthe sty dog not be alowed to eteape becawe, it were to cocpe, tae ‘ite victim would have to recive a seit of rabies aot that cull barn Oe tt raSeptember 17,2016 Page? being oF her uaboen childs 5. Offers obtined the telephone number foe the stty dog's tag and «patel officer ile the number to teach the owney, but when the numb was ded it was aot a ‘working number, 6 The responding officers struggled to contol the say dog for upto an hout before Agent Bolger nally used his knife, 17. Agent Bolgee made repeated and numerous segues for Animal Control to seepond to the scene and tke up the ny doge ‘The police command could not povideeren aa estimate of how long it would be before Animal Conttol might responds 9 ‘The Bakimore Police Department peevooily provided the Emesgency Services Unit to which Agen Bolger ws asgne, witha chemical to euthanize asa, but at ‘was discontinued ia November 2013 for setons untebted to the necessity of an ‘officer occasionally being called ypon to eathnize a nial 10. Agent Bolger did ot “sce the dog’ tout” as has ban reported equa, but ‘nacre, i the media. Tn fc, Agent Bolger made a suxpial ncson that severed the stay do aco artery and 11 Agent Bolger never side was going to “gu” the dog, as has been incorrectly and ‘shodetousy reported in the med der citcumstinces such 28 thest, the Balimoce City Health Code authovies « Paice ofcerto euthanize an animal Section 10-705, provides, a seevant pat 16» 4 pie oficer «finds an animal st ng, and ifthe... poice lier... reasonably believes that the animal is avout aizal aad tt the animal cannot be ten up or tanquiized and impounded, the police offer say kil the anil “Vicious asia” means any animal dat: () bat severely bten or stacked a Jmoman being... Da City Health Code, § 10-7030). Inlight of the excupatory facts cet forth above and the Bakimore Cty Heakh Code ‘hat specifaly authorizes » police officer to eaanize a animal in these ctcometaoe, sina cases apie Ageat Bogr ate unearited became they are tot supported ‘probable ows. The Marylnd Roles of Profesional Conde! provide tats “prtoenonSeptember 17,2014 Pages 4 ceiminal cave shall finn fm prosecuting a charge tat the prosecute knows isnot supported by probable cause” MD. CODE. ANN. §164812, MPC 38 (West 2103), Probable case is “ceasoanble cus; having more evidence fo than aginst” Black's Lay Diccionaey 1201 (60h ed. 1990). That is, “aja apparent te of facts found to ext upon teasonableinguicy (ti, such inguzy asthe given cae renders convenient and prone’), ‘hich would indace a zssonablyiteligent and prodet man to believe, int erminal ee, that the aoused person bad commited the etme chued == Td Gavernal cist, comin, ‘Thecefore, we ak that you dsm the charges and termiaute this ease. Shoul you nevertheless petit inthis protection, which we strongly oppose, we ‘cognize that one way to cure the defect in the manner in which ts ese war egal shaged is to dismis the charges and present the ete to tad ey Jn the event you elect to do so, we roqust that meanues ae take to ensure that Agent Bolger receives the benefit of applicable conttntonal protections befor the grand jig. We ask you to present ll excalprtory evidence tothe grand jury ato lost the {and jy on the relevant provisions of the Baliznore City Heath Code asst forth shone ‘We sso request that you szsnge fora recoxdng or transcription the rand jury preseason, ‘loin all testimony and statements before the grand jay, inching the watimony ofc swtmeses and all lp instructions given bythe Ansett Sac’s Atexney@), to allow for Sere julia review. The Inw makes dear that ont rages in this sop shoul be honored, he ABA Cina Juice Section Sunda, spprved as luck ter” standards by the ABA Houte of Delegates, provide that a prosecutor, who scales adrsor tothe and jus may “appropriately explain the law and expeess an opiaen on the leg Sigiicance of the evidence but should give due deference to [he grand jury sates asm Independeot legal body." Moreover, “alo peoseestor shuld knowingly fal dicore te ‘he grand jury evidence which tends to egate ui or mite the ofense "= Coutts have recognized the fandament ebigtion of» proseewtoe to stk justice in {8e end jury, and not merely to obtinan indictment again an accused wathout fepard to fe dealing, “While te protector’ diction in presenting he ese tothe grand hey ‘woad, it ts not unbounded for itis sted eat ats Grad Jay proceeding, Be prosenee Performs the doa role of advocate and pubic office, caged with the Sty tot eny o> {AA Ceniol Jone Section Suni, Protection Funcon Sand 3-35() (1992) anal at (tp fewer amesianbacoy/ keaton eimai section omg imjus standards pone ocd). "id 2 Standard 35.5).Septeber 17,2018 Page secur indictments but oto se that jac is done a public office he owes day of fut dealing tothe accused and candor to che con)” Pag, Lamas, 69 N28 2 36 (1986) Pape v. Pel, 62 NLY.2 97,108 (1984) (the prosecor “ie charged with the duty ‘ot only to seck convictions but also to see that justice is dane" incon inthe grand uy) ‘The test for when a prosenstor nme prevent laa exeulparry evidence toa grand jiny tans on the poteatl ofthe exculpatory evidence to make outs complete defense or fo ‘liminate a “ocodless or unfounded proseeation”™ Papi. Vale 2 N24 36,38 (1984), sai Laneatr, 69 NY 28 at 26 (986). Whee the evidence makes oot a complete defer, x eliminates a needless or unfounded prosecution, ihe prosecation' tet pete that ‘ridene wo the grand jury dictates the dmisal of the indictnest. Valle, 62 NV 249438. ‘This duty “of fir desing extend not only to the msbmision of evidence, but also to instructions on the low..." Lasser, 69 N.Y.24 at 26, Thus, when the poosector “invtucls) the jury with respec to the sguficance, lea effet or ershation of eidene,” CPL. § 19030(), he must be guided by his day offi dealing to che scoured. When be as ‘in this duy and his instrwtons are to “defictent as to impel the integsy Of the Grand Jnay’s deliberations” the rvaking indicment must be demised, Pape. Cans 210 ‘AD 2a 164,166 (34 Dep 1994}. We invite yout contact us dined to discus the prompt and appeopsist resolaton ofthis cae. Very typos, Cases N. Case Steven F Levin Sarah F Lacey ce Paul W. O'Coanos, Faq, Rebecca Wood eg2” [na More Stones About Lawyers for offeer accused of killing dog sek Bornetein to roconeidor ace (© | attire eens isha seatiaceyremncrrsne" By —__ se Buy Home For Taxes | Alert: Buy This Stock Owed | Now sntanesenencormeecause | epstciansnscon “Tp ves Real sucess Ste Ths ny coul src Ag Freecorse asm Uintah BoekeSSrrterenrnsepureetcctcrecapecren teeta tangs Tapert sa nnd at Arrest Records: 2 Secrets = ‘Ermer Sar ad Ste 2) Aces agen Lhe tn esenae Become Ordained Today : erga, Odaned Miniter Registation Reger Now [Scene — { pesheromttoeyam «aroun | 12. Frue Power of Attorney Form Adopts Reored Potce Dog i | «ote Ssevsemsimmmes | | Sermemenuayon oar Se SS | ——_ == are eeeef vant f gard PE ae Medicai ’ What Gregg Bernstein has Malpractice ‘accompilahed [Letter] G) Bakimore medical ‘ie omg tna mn tn 8 te yn nn malpractice case? Mlllons,— Srojcesanseuy tunareretcetwnpuanensorteeeteeebe ‘ecomred forcients* (aang snatunnsonersarreme ceva et rentakstoncom| | Ron Bankston san experienced attomey {and mediator. Book now. last cea Eearnn Teens ane ‘omsepamocnuwrnarnnt | mv test or hgianranio be yt era arasrona Arizona Collection Agency s dbheredam or memncae Maxie Your Recoveries Conpeve QuoesFl SeveTae tomas So kace cout Spat: Creu Court for tative Cty Criminal System Jew numer: 614227008 Core Sats, CLOSED Status bata: 04/06/2018, Tracking Number: 087024003231 Campsnt a: XFO403 Fang ete: 06/18/2034 inant Onte. 06/14/2038 [pstandan Sofermation bctenne Nee: SCHIRIDT, THOMAS ace wate Sex: MALE Dos:08/ 8/3963 oy: ABINGDON Stic: MDZ cox: 24000 (ach Charge hte separately. The positon feted belo the Charge} frargene a Iousytate case: § 0505 Jpsocstion: WOLLE PROSEQUE Depeston Cate: 01/08/2088 sya Code: 3 0808 focsxeon: MUFILATE ANIBAL, loiposton: Nowe pRoseauT osetion ost: 81/08/2048 sratie cose: & 0500 Desegtor: ANEMAL CRUELTY loinoston: NOLL pnosequr bsrction be: 08/08/2038 lcs/ate coca: oxonaa Descistion: MISCONDUCT IN OFFICE lveoosnne: | NOLLE PROSEQUE Dsposison Dats 01/08/2088 me-botaeR, seFFaEY @|Adscee:7067 SADDLE DRIVE [civ: ELDERS@URG State: MD Zp Cove: 21784 re: MENDRIWOS, NIKOLETTA conection DEFENSE ATTORNEY aarecsst SOUTH ST 29RD FL [oy BALTIMORE Seat: MD_7p Code: 24202 ene KOEN, MARY. contin: DEFENSE ATTORNEY aaess:t SOUT SF. 29RD FL (cy: BALTIMORE State: MD_Zip Cove: 28202 ecouseanae, PAULA conection: DEFENSE ATTORNEY Jscress:1 SOUTH SF SUITE 2300 sme: OcONNOR, PAUL Ww |conecon: ASST STATES ATTORNEY ncrss:700 & PATAPSCO AVENUE Jory: MALTIMORE sace: MD. io Coie: 21298 amo: woODs, REBECA Conecsoe ASS STATES ATTORNEY |ncress:700 . PATAPSCO AVENUE. [Sty WALTEMORE state: MD. Zip Cod: 21238 me-tA-vi0LA, ANGELO D anncon POLRCE OFFFCER acress:TTERNAL AFFATRS O1V ccres:tDUCATION & TRAINING SECT ress SOUTHEASTERN DISTRICT phe MIDDLETON, HENRIETTA L Cnectan-POLIee OFFICER omesmuza, MABEL conection: PoLReE OFFICER arne:FATCCO, JOMN R |connetn-POLECE OFFICEREvent Date Comment JCASE 08/15/2034 CASE ADDED THROUGH ON-LINE ON THIS DATE 20140819, FILE 00/20/2014 FILED ADP - MENORINOS, MIKOLETTA, £50 So0ms0 (20/2018 FILED ADF ~XINIS, PAULA. ESQ 341678, IHeAL 8/2/2012 P1sjossoy4ae anno; ;CONT) ;JONES CYNTHIA for? Wea 09/31/2014 17;0830;636 ARNG; (POSTICANIACKSON, rMLIF/ BES ICOM 09/36/2014 mor1ON To compa DISCOVERY ;HCKLE DATES 2ou40024 00307698 ARR, i wea 99732/2038 Pa7jossoyese many OTHK)/2ACKSON, PRILIPGED FILE 09/25/2014 FILED ADF Koch, MARY 680 572036 47;0200;836 ;PMOT;;CONT; IACKSON, PHILIP;SES "17;0300;696 ;PMOT, ;POSTICAN;SACKSON, PHILIP/BED 4702007696 jPMOT;;POST}CAN|2ACKEON, PHILIP OED 47/0200;636 ;PMOT; jPOST;CANJIACKSON, PHIL luca 32/22/2034 17)0230/606 PHOT, jOTHR; AACKSON, PHILIP HEAL 01/09/2035 pz;1100;404HaRRG;NP;DUDG; PETERS, CHARLES; OE. locas 1708/2015 CASE cLoseD- MOLLE PROSEQUI-Q3I7 rt sn lect case record, Fl case information eannet be made avalible ether because o lage! restos on access to case records found Maryland res 16-1001 though 16-101, or basiet ofthe brated inerent In reduc 2 cee record into on cron oat.(r—The cay Sacre planned ay rece ey test, the cy wert up ‘ove ron ut oot Bains han te wks te 25 year men ie Ima cutoay, Wat ries pce pots dys apo have hed la, wh tore eg oe ck ‘bola tun at ples an bulnge and ear enton es, we know happened on Mons lesa pt the leno:Soe Teste’ cvlpmants Westra player on ‘Preis gat we {1800 asm, ~The fen x Fel Gay sett bog, nea ‘42 pm. ~The casket alg Rcd Graysb0dyis epot: Tom raya leaded orton hare, roof Dtatgste 2c 00pm. ~ Aro-cae ro ach ett aeeae fersbate pope stead sat congo sai Sesminor Son Tet To Pe sone {ean sot we cra ne Ud SS Stes ocmine altar snpenced roe er Seon roves » potad wey yor = ‘0 pom. 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(28 pam, ~The CVS hat was ote gee Up in are, (647 pam. ~ Gow Lay Hogar otic mens ht rl chard eves on clan on Tons il bce 6:0 9m. ~ Amn canbe eaen on CNN satng aoe tha elearning ou Boston bowers deans “_lechaged noted 18 ‘lotors cut water hose tying to put out re 01:57 ied lt "01pm, Goe Lary Hoga’ fies aramines that he has deca tal of regency and ‘arte th Hasna Quarto addins the urea Salmo, 20 pam. ~The Os smnounce they patponed Moca ight’ gae,=—=_ C=) ‘er ost wn Blin Cy Pac Depart ter gee teen Ce & He ,, Sra Ota Pasta teenponpane 788 pm. Batnre Mayer Stephanie Rawings She anne ta clyde, iy ctw wl benpoead staring Tes fom 10 pn fo Bam lb not one we, Feng Bae ald ts rte conference £251 pm. Covi Palos of ha Manan Sie Po racuncs that pt O00 ‘xfrcement ofc wl be eqused tom he mis ane agin lp eu te tren ‘nine ‘2pm. — Pui scat wi be cose on Tuesday Elinor, cy fel ey Deslenichirg Owe Manone ceeyasrnts of io fihend ipasnayvaim.. Penaus ‘Muse the Cunsiet Cat Ever and He ee ee ee ow ad Free Gray res in? Looe nE IRAE SS omc eanon iene ‘Hor’ Frases Your Customere ShoulaNevor eam Supt Tau laytaainnGiem Gostx mPagury garearreernee ee Vogue tevete'Loxtnareanae Rea eLae 14 Tes Ke Wet Showed Ot ae Than ‘Avant oe riod 12 vnc bg ot Dade ete chat nn PosesExclusive look inside the Freddie Gray investigation eatin George ‘Re taninae sat _2utztsoorcotrene oom tine po haut tll ena eT hia Hoe ‘ant lowered themselves onto ha ara nr tn demons tng hd oferta recta Pee ‘Gray the aye was rected ~ and stad tl pine nay As neofcr played Gra’ oe, hing fe Zownon the os, hohe be it rowed es bck toward bse ‘Watching closely were embers of he pole afore nvetigaing Gray's, and De. Dad. Wiggins ‘Maryland orthopedic surgeon wo hae worked withthe US. Oj am Higgins had aren reviewed xiphone video showing the 25x art a Wet Bmore inching soe him ling spine potest ofices aged hn tox trngport an Ni, Higgins was nbd what jr & Peron could afer sch eg al, "rom tht mabeinerevefyou dammed bin er opp him He wretig move, yo il won ave a seule! injury eld Higgins, conning to explana more deal. “OK si Ma. Stanley Rendon, the Homie Ui commander who lathe tk re, Ho mark snther tse «complet. Another aaton aout Gry was aneveted. ‘The scene on Thursday wa part of high-stakes pole nvetpnton— and came a Bainare was eling on rote thatbrovght husnds of marchers, nd some vse toy sess, neatina enon wa focused on ‘hey and many residents were proteting lege ple bratty ond eager ermal barge. "Thu Buimore Sun as ranted excise sess tthe to fre nd moitred the nest fr dye The San reed ntto pubs dts aout he nvestigaon ual Bahinore Sta’ Aterney Mar Mosby Ceied thro prosecat any ofthe fried in the Gray nant. though eperters conned to er ther eorces for iformtion. On Fri, she aoocnced charges gan oer, Meaty announcement came ats dye ale povided er wth lett eport on ther probe, bt posers 2d conferred with lic fom eto ine and Mosby si the slo ed an independent eam of avesignto Her ‘nounceent iday tok member of the ples tak oe by serpin. cr acne tothe ask fora hd been working fo two weet complet an avestigaton tht might there ‘ave ten month. The craved West uimore or winetes tnd mnpped onthe neon ef seaityeamere footage, To erat Gray's minut rin police ar, plancltes ocr red $230, 000lasr ming stem moa ow ptboie ronda eracedtdevales, rad totell residents win questioned them that ey wone etysungers,‘Atleast go member ofthe Poe Department were pulled onto he tek fr nding staff te eine ab, ‘Foreign Team, Internal Afi, Hom, nd eutomoil CRASH eam. Bath bop with tes ‘apertineo hp anoverthequations a vate cy dempertly needed how Gry suoed the rere spin nd tbe ine tat ed toh ath on Ape 9, a wodkar his rest ‘Ty allele he importance ofthe investgation and hat they were pata pital moment in Balinore soy. Thar were n dao, "Ase ible" Col Carnell Gren tol theta forse Thad ming. "What happen rst on ou sen sas tasha ‘Te veiation was out of ren onrence oom nthe Adrinsatve Buea Members ofthe tore tne thereto, somes thee ime dy, aba arund two large abe hat had ben pathod tages. They ‘played chest to haep rock of thal lnveatation, ond thet re dally ut ha gga oany ‘compete, some ill open ~on Tardy ‘On ene wall was timeline tht ted Gra’ and lof the pole v's, Each point onthe nein was cotta wt ites of ray, th ofces who fated with him hilo timestamp and bry sere, ‘ots taken rom uevelane vdeo, On anche val, autpay phate of Gry stared bak nena colorcaced map "tng lth pat and pie sarvene exmeras long the vanes, bck was table wth Gatorade nd rater bots ‘The tas force worked wie beng unable to question th sc offers, ny nl statements the fers had Provided. Detectives wer told reconstruct the fees actions not oly for pi zt several dyed een yrs i ong internal ecards andes" which goer ly stons, Wii xc tk ore member oss on spec tak —Snterviwing witness, saving sich warts upésting« “thing” inline frets — 1p-eecomsnander lake athe bi ptr withthe Police Departs rd nnd Tey knew the investigation wuld be psd part by many people in akimor, inching the thousands of ‘rote outa tir dor. An the allepos ort, hey wate to nw tha they woe lve no tone, ‘sete They wanted an set foray question prsestory, tore andthe ube might ‘They focundon the task fgtheringnfrmaton, and showed og of confor we averting coleagveson ‘epi foree—hnorng tht the con to bring exinnal charges wou est with Moat and net than ver and ves hey they "weal foo wherever th evidence leds” {avetgtr treo dterine what happened ding the foot nd bee case hat preceded the tkedewn of rey Di be fl? Had Gray ben nat pie othe rest? Waste Inte rmor bout en sane tment {ora caraciest tv tas not), When wash iting and when washe rons" withouta eat be, nthe van? Task force memes contin’ to lnvetgatall sities een tvagh the lt condent that ray hd sured e "erestopic inary’ he eing taken from he are tier Homes the Westen Diet ple een They _Secoveredthat th vase exnera wat rohan and that oe oth eices drag he anepr eld Gray had “lt” ~ a fad ness ~ ehh complalned about a codon "osens een soem me mt emanating roves‘And tht pet many hours real th action of Ofer Cae R Goodson, rte wagan der. Goodin, the nvetatrs sid beard Gray for metic eps number fines ~ ay fut the hares Moby wool wing aga him, Si, there wer gps slong the ote where novo or wines atemens exe ‘Thelnveigatr snug to undrstind why Goodonn had made sop tht was dace ina review of Video camera ‘tage Albay coud deternine vas that Godson laced int the eek oth an but i ot oud Gr Bat hey ‘wondered: Werther other stops? To find eat mere shout havan ost, fcr tokio the sre ‘as Sunday the spot Gray ha been arsed mslahitmemaralncidd ign that si “TExpletie the te. two lal 6of bitches A half ok away, eee chan Tos Winer nd detectives Miche! Boyd and Timothy Hanon role the laser imaging deve tong a wheded yl ep, They wee Tabet nd cage ana tep low pole nd ao long conventions or wor a.cniotation in neighborhood where rent? ‘ge wat tl ram vile prota the previous nigh. "Oooge-eam rollout Boydell ~ joking reference to Google mapping cit — ter the ti fished a seton ofa, ‘hey had eat 70 sans to do, cach king ceclr image afr a GoStay, and ath tie meta complete them. (On the der sy ny, hey wet about ther wrk wot any intererenc. One man walled witha rosin plat ‘ote thats ised given him A mann ear slowed to sear tp batten moved on No one eal aed what hey weed, ‘he Google tun” canned sects and avenues Prsbary Cumberting Clouse, Dolphin and Del, ‘Winer, whole nts swor fir, was take with ting detailed malt-mension map tht wotk! show the ‘route and tenn. Hib stoping ttc the ape othr the vena path was recrented eos ‘hat was ony pert completed ty the ine Mosby anounced he hrs, Token by surprise atest wk Bradford the hamid commande, i eel "ouien soot whee hs vetiton wat ‘oat, bate nvr lok eto an explanation for Ga’ spine ry. Hele open the post that Gry wat ene or bailed to rou. ‘We i guns strong fara this ta forces concn. Wheto Si fitigu het bis ea “Tet ‘confident we hve sold ease here bt weal ave things to da” (On Pay, more remsaed The taskforce was planing to go fl-bre stright hong he wekend eng ‘sopplemectl eporato Moss oe and the invengaton wast renin ei indy, scoring ‘rantord. “Tmprtant thatthe sates trey eatin to pt things as we alt hem, end od his red memes Fide morning,‘Tenis eliphonerang, Hestepod ft th bl and did’ return, Mime later member found ou wy: Moy wat hing neve contac on the tap oth neiby ‘abinore War Memo Pom eaecrentelevson in Gres le te watched ave needs ‘They sood motionless Most bean spesng Aleut wesrng sult nd owe ested hele hand ont | leather cha even stod suf gun the wal and bend his back As Moy ed off the canon incutingncnddere depraved rer, the serous Ooedon ~ sna ooa tre hele ‘hoe. They had not expected the sta tore to cso. {aterm dy, Moy edt charges verte en of roses ering ind 4 Aou dae ong poe ‘evetators. She ho ah pronmstrs ad been woking ona paral invtpation’ that inlet uring ty ers depuis (Tis wes not something that wa ik ft and in hay” shee. We revewed handed of bors fame ‘Wotege an ates, Tis ismetlg we worked ell hard to ptt the Bota of ‘tl eny fits eine onthe pai ts foe chek. Members soe wer back thr nvetigaion Sveorge@ baton ter com/pustingcorge eee 02018, Bin SeFOP calls on prosecutor to recuse herself, defends officers By Doug Donovan ‘The Baltmore Sun Ay Rina ede cee og ig Bains Sate Atay Maryn Moby appoint Prosecutor tothe Freddie Gray investigation because of her pereonal conection to the Gray falls torn, Willies H. "By" Murphy Je andher mariage tally coun, ‘Th letter fom Gene Ryan, president of Fraternal Orde of Police Lodge 3 abo states tht none ofthe sixfcers ‘volved in Grays arrest and death were responsible forthe 25-year-cld West Baltimore man's desth tet spared ‘rests and unrest, including iting and looting on Monday. The eter was released ust mites before Mosby ‘snnounced charges against the officers. "Wot one af the officersiavolved in histragle sitution left home nthe morning with te antcpetion tha someone ith whom they interacted would not go home that nigh, the lta sates "A tage this situations, none ofthe ices involved are responsible forthe death of Me. Gray" yan quests that Mosby appoint a "Special Independent Prosecutor” “Thnave very dep concerns about the many conflcs of interest presented by your office conducting an investigation in ‘hiscase"theletter states, “Those cons include your pertonl and professional rations with Gray fail attorney, Willams Murphy, nd the ead prosecutor’ connections with members ofthe local medi, the ter states. "Basd on sever nationally ‘elvied interviews, these reporters are ily tobe witoeares in any potential tigation regorng this incident." urphy supported Mosby during her campga lst ear. He donated $5,000 to her eampsign and served on her ‘uation comatee ‘na statement to The Balimore Sun, Moshy said he Gray cas doen pose sy confi forher andthe police union onated to other candidates in election tobe the state's atone. "State's Attorney Mail Mosby hasbeen elected bythe reidents In Blimore ity to uphold the awn every "sghbotbood including her own, regardless other husband i he councman within the ditt where numerous ims os" nid pokeawornan Rochelle Rite. "Hundreds of poople donsted to her empaign There ino cont oftnterst urrounding Billy Murphy. His representing the family in cv cao which has nothing todo withthe criminal ae.” ‘The FOP letter aso expres probless with Moshy’s mariage to Baltimore Cty Coupesinan Nick Mosby. "Moat importantly its clear tet your husbend’s politica future willbe dirty impacted, for beter or wore, bythe ‘outcome of your invetigtion," the etter ste. "In order to avoid any appearance of insupety ora olation oftheFor ano preston eal, endows tn ee ers. s00 ‘Professions Rules of Profesional Responsibly, ask that you appint a Special Prosecutor o determine whether ot ot any charges could be ile" ‘The letter continved: "Werecognie that there are many mensions to thi situation: he publ satiments —on al ede; the investigation ‘being conducted by your office the internal police avestgtion; anda necessary review of the too equipment, and ‘eourersaforded to Baltimore pole officersin order to erry ot their sworn duty asplieofcers ‘The letter ao sats thatthe oifcers involved inthe case are “ner dened by Mr. Cy passing “They areal committed police officers who have dediested thir caret tothe Baltimore ity Plies Department," he ‘ites. “And that hasbeen fost in lef the bly. All deh tape. And death asocatd with interaction with police isboth shocking and frightening tothe publ "Bach ofthe ofeersdigenty balanced ther obligations to protect Mr. Gray and discharge thelr duties to protect the abl the tte stats, "T hve flat n your professional integrity. While Thave the utmost respect for you und Dour office, have very deep cones about the many conics of interest presented by your eles conducting a, investigation inthis ase" ‘Doug donovan @balteun-com Canyiht ©2018, The Bakar Sn FROM AROUND THE WEB ‘Soren Ue ig Data & Anatyics Fosters Contnuous Learning in Business This Where You Should Be Hiding Your Spare Key ‘Tre Haroraue \When Someone Dee, Howto Say Goodbye ‘Tho #1 Reason AmatoutGofore Cant Ove 2006 Yard. Hark Haney Unery Saving Secrets The Rich Wont Share oBentngRatcom ‘os Never Balove What iin A Sin in‘Heres What Deney Princesses Would LaokLike With Normal Wsistines FastCompany ‘The Coolest Tatoos You Ever See ‘erate comtaeumadttoe hm pti 808 -oyamAQSOW Y9IN }ouNsIq Wounog wp i euowigieg jo AND"RANSON Met cuter ten Fe iy et RY Dy we const K NEW YORK NEWS POLITICS SPORTS. ENTERTAINMENT OPIN Marilyn Mosby announces criminal charges in death of Freddie Gray: 'To the people of Baltimore ... | heard your call.’ (TRANSCRIPT) srwcotevensiey CEHEY) 1 yew vORKONRy NEWS / tc Fay. ny 201, 2.06 PM 1 Ul Fo 3208 923 AKA “ = * sane THE UR rnin pw Baltimore State's Attorney is Youngest Chief Prosecutor Major U.S. City _ Daly NoweTRANGCRI Mat amcor gen Fe ay eth-MY Dyan conser waar Aontictmtt'se0 stem tape tnerrpeacoens (Ef srt pounce con Laan a peaceaar cara ocaransree “Ineed to express my pubic sympatios ofthe lred one of Fredo ray. axe oprriniy toes wh Gray'samiyto dics some ote cea cf HUB ostbyor te cae ane posal eos gong var Ieee ay barra Satl SSR SE cei cioveaw ier anttmet oc prsuspetce nab baan co Tose wands fy resins, cormunty oxen and fath adr and polit leaders that chose to march peacefully throughout Baltimore, | commend your courage to stand for justice. | seo commend the brave men and ‘women both in uniform and outwho have stepped up Monday Night fo protect ‘ur community from those who with to destroy it ‘As the oly’ che deputy prosecutor Ivo been swom to uphold jute and to ‘reat every individual within the ursdcton of the Batimore city equally and fay Under he aw. take tis oath seriously and | want the public to know my ‘administration is commited to creating afar and equitable justice system fora No ater at your occupation, your age you ac, yourelor or your reed. it SOM 's my jb o examin and vestgte te evidence ofeach case and apply those AE facts to the elements of a crime in oder tomake a determination as to whether Eyer toss nein Frode Gray eo indhiduals shouldbe prosecuted, This ea tremendous responsibil, but one | aN MRAP HESY saw and accepted when the citzens of Balmore city elected me asthe state's ‘Money ands rece wala ne coe oe Gy ba pont STASI MARILYN MOSBY BECOMES NEWEST LAWENFORCEMENT STAR Dat (Once alerted about this incident on Api 19 vestigatrs om iy ple repty uit were deployed to inverigate he ceamstaoes sounding Mr rays aporeension Overthe Bia course of crindependent investzatn, in ve uel oat of Me Gay, my wan werk around heck 12 and ‘4hoxrdayetocamvasand PROP coon at es echt RO weetInteriow dozens of winesses: iw numerous hours of video footage; repeatedly reviewed ‘and stoned to hours of poo video tape statements; surveyed the route, reviewed voluminous medical records; and we leveraged the information made avaiable by tho police ‘department, the community and famiy of r. Gray The findings of our BS = ‘comprehensive, therough and ‘ccmmonerromonriens funn ac yn Mesy ata pens conference ftneuncing Bo chargenspurat six Batmore Gly Foes coupled wth the medial core inte death of Fred Gay arestonFisy omng. Sear datcrinaion ha Me Gray's death was ahomicide {hat we recived today, has led us o believe that we have probable cause fo fle ciinal charges. FREDDIE GRAY TIMELINE: THE EVENTS LEADING UP TO HIS DEATH IN| BALTIMORE POLICE CUSTODY ‘The statement of probate cause Isa fllows: (On Apri, 12 2015 between 6:46 and 8-16 a.m, nea the comer of North Avenue ‘and Mount Steet. Lt. Rice ofthe Batimore Poice Department wile on bike Pato with Oficer Garrett Miler and Edward Nero made eye contact wth Frade Cartas Grays. = ata Heving made eye contact win Mr. Gray, Mr. Gray subsequently ran from Lt ‘ent ice. Lt Rice then cispatched over deparimentalrado that he wes involved ina ABH footpursut at which time bko patrol offeers and Nero began to pursue Mr. Gray. tide cone ncotnc win taraung er toy seed oan Aber and Nein te vanty to 1700 ok ot reir Set vt ce titer aN then hand Me Gry and eves hin aleaiona St tow ot way fom ie surenderngiciton ty Grajwaathenpaeaina Sl Pore poston win is arr anda enna bck ver tte het ote"RAKSONPE ony ssa nage Fee ay nay ater ara Phot Viet Freddie Gray is ploture being arrested by Baltimore pollee officers the moming of April 12 afierhe ‘an roma pal ot bleyeleofieers on patio ano ‘Mr. Gray indicated he could not breathe and requested an inhaler to no avail Hand Ocr tile an Nero hen placed Mr rey navel peten and ad substantially founda kife clipped tothe inside of his pants pocket. The bade of Tot the ke was folded into the handle, The kife was neta switchbade an is aun lawful under Maryland law. These oftcers then removed the ve and placedit = onthe slaewalk. Stuc Mr Gray was then placed back "OL down on his stomach atwhich at time Me Gray began to allhis roulegs and scream as Officer Miler Germ Placed Mr. Grayin a restraining Passe technique known a8 lg lace, ‘While Offcer Nero physicaly held him down againet bin wit ‘hile a BPD wagon arrived fo transport Mr. Gray. LU Roe, Offer tt and (fcr Noro fed to estab probable cause for Me. Gray's arrest as no crime had been ‘commited by i. Gray, take Accordingly Lt Re Officer vig Mller ane Ofice Nero ilegally arested Mr. Gray. Upon arrival Shoe ‘ofthe transport wagon criven by Officer Caesar Goodson. Lt. Rice Oficer Miler and Officer Nor leaded Mtr. Gray Ino the wagon and at no point was he secured by a seatbelt wile in the wagon contrary to @ BPD (goneral order. Lt. Rice then

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