List of documents - 4/11/2024:
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Organizing for clarity in order of above list:
Document 1:
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Document #2:
MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT ALLEN'S MOTION TO SUPPRESS
(Here’s a quick UNFORMATTED copy and paste text version of MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT ALLEN'S MOTION TO SUPPRESS:
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Document #3:
Wow, looks like I missed all of this yesterday.
I would say isn't it coincidental that RA's most bizarre and 'crazy' behavior occurred after the State gave the Defense (who in turn shared with RA) its major Discovery dump. Hmmmm. That's when he 'snapped' and started eating court docs and all the other crazy antics the Defense is suggesting. I believe they all agreed that RA had to act as crazy as possible to account for the confessions made to his wife, mother and whomever else.
There is NO EXPECTATION OF PRIVACY in jail for any inmate. None (except when speaking with attorneys). If RA was blabbing confessions to everyone coming and going, those are not protected conversations. How many defendants have been convicted in part by the testimony of cell mates or other prisoners? Countless.
Being yelled at all hours of the night by other inmates, the size of his cell, his suicide watch precautions are standard. That is what happens while incarcerated, I can only imagine it would have been worse for RA because of the charges against him, ie child killer etc. It would have been the same in a local jail IMO, but much harder to protect him.
RA had access to medical and psychiatric care while incarcerated at Westville. A high profile defendant is not going to be denied that access, if anything, I bet he received more access. It will be interesting to see what the Dr. and nurses who interacted with him observed.
It all comes down to this for me:
RA started acting 'crazy' once Discovery was dumped on him and once the Defense found out he made those confessions to his wife and mother on a recorded jail phone. He amped up his bizarre behavior for a couple of months and then miraculously went back to normal, ie eating, showering, sleeping, having rec time again etc.
That kind of behavior would be impossible to keep up 24/7 for a long period of time when you are not genuinely afflicted by serious mental issues. He was fine from Nov 22 - until April 23, then went off the rails for a couple of months, then back to normal a couple of months later. A seriously mentally disordered person cannot turn it off and on like that.
The Defense had to address the elephant in the room. It will be easily dismantled by experts IMO.
MOO