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Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page 13 of 38 in uncovering admissible evidence, aiding witness preparation, corroborating testimony, or assisting impeachment or rebuttal.” United States v. Marshall, 132 F.3d 63, 68 (D.C. Cir. 1998) (quoting United States v. Lloyd, 992 F.2d 348, 351 (D.C. Cir. 1993)) (internal quotation marks omitted), Courts have interpreted the scope of Rule 16 (a)(1)(E)(i) broadly to ensure that defendants such as Mr. Thomas have a fair opportunity to prepare for trial. United States v. Poindexter, 727 F. Supp. 1470, 1473 (D.D.C. 1989) (“The language and the spirit of the Rule are designed to provide to a criminal defendant, in the interest of fairness, the widest possible opportunity to inspect and receive such materials in the possession of the government as may aid him in presenting his side of the case.”) Accordingly, the “materiality standard normally is not a | heavy burden.” United States v. Stein, 488 F. Supp. 2d 350, 356 (S.D.N. Y.2007) (quoting United States v. Lloyd, 992 F.2d 348, 351 (D.C.Cir.1993)). Lloyd, 992 F.2d at 351 (internal citation and quotation marks omitted); United States v. George, 786 F. Supp. 11, 13 (D.D.C. 1991) (the materiality hurdle “is not a high one”). The requested documents in this motion are esseniial to Mr. Thomas’ ability to prepare a defense. Mr. Thomas contends that the conduct with which he is being charged is: 1) rampant throughout the BOP; 2) made with knowledge and acquiescence by the leadership of the BOP; and 3) is the direct result of BOP policies and mismanagement that forced the defendant to engage in conduct for which he is now being charged criminally. Moreover, the information sought in this motion is crucial to the preparation of Mr. Thomas’ defense. For instance, Mr. Thomas will assert that the rampant staffing shortages present at the MCC in August of 2019 led to the conduct for which Mr. Thomas is now criminally charged. If the Court accepts this representation, then the Court should find that the discovery requests contained in this motion are “material” and must be disclosed. As support for this position the defendant has attached an excerpt from a union committee meeting that was held merely 3 days before Jeffrey Epstein died at MCC on August 10, 2019. The attached memorandum memorializes a meeting attended by Jermaine Darden, the captain of the MCC, wherein he was vw DOJ-OGR- 00022036