Home/Source documents/Court filing — United States v. Bock et al. (Feeding Our Future) (Dkt. 208, D. Minn.)
Court filing — United States v. Bock et al. (Feeding Our Future) (Dkt. 208, D. Minn.)
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CASE 0:22-cr-00223-NEB-TNL Doc. 208 Filed 12/21/23 Page 1 of 2
UNITED STATES
DISTRICT OF MINNESOTA
Criminal No. 22-cr-223 (MJD/DTS)
____________________________________________
UNITED STATES OF AMERICA,
Plaintiff, DEFENDANT AHMED ABDULLAHI
GHEDI’S MOTION TO DISCLOSE
v. AND MAKE INFORMANT
AVAILABLE FOR INTERVIEW AND
Ahmed Abdullahi Ghedi, TO DISCLOSE PROMISES OF
FAVORABLE TREATMENT
Defendant.
____________________________________________
The above-named Defendant, Ahmed Abdullahi Ghedi, by and through his attorney,
Glenn P. Bruder, Mitchell, Bruder and Johnson, and pursuant to Fed. R. Crim. P. 16, Roviaro v
Untied States, 353 US 53 (1957), Brady v Maryland, 373 US 83 (1963), requests the court to
order the government to disclose the following information:
1. The names of any and all reporting persons, informants, or witnesses providing
information to law enforcement regarding this case.
2. Any and all promises of payment, written or oral, made to such person as part of
this or any other case in which they have provided information.
3. All promises of any other benefit, written or oral, made to such persons.
4. All promises of immunity, leniency, preferential treatment or other inducements
made to such person as part of this case or any other case in which they may have provided
information.
5. All writings or memoranda which contain any of the promises of remuneration,
leniency, immunity, preferential treatment, or other inducements.
6. Any record of payment of funds made to such persons.
CASE 0:22-cr-00223-NEB-TNL Doc. 208 Filed 12/21/23 Page 2 of 2
7. All information regarding any such informant’s prior testimony in this or any
other proceeding in which they have acted as a witness and/or informant. See Johnson v Brewer,
521 F.2d 556 (8th Cir. 1975).
8. All evidence of the informant’s psychiatric treatment, if any, or of any addiction
or propensity to use or abuse controlled substances.
9. In addition to the foregoing, Defendant also requests that the government be
required to produce the informant for an interview by Defendant’s counsel.
Dated: December 21, 2023
Respectfully submitted,
MITCHELL, BRUDER & JOHNSON
/s/ Glenn P. Bruder
Attorney for Defendant
9531 West 78th Street
Suite 210
Eden Prairie, MN 55344
(952) 831-3174
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