From the 4/5/2023 Emergency Motion to Modify Safekeeping Order (hearing was in June, JG's denial was in July):
i. Attorneys for Mr. Allen delivered nearly 1,000 pages of police reports to Mr. Allen on Friday, March 24, 2023, with the intention of seeking their client's copperation in his own defense. As of Monday, April 3rd, 2023, said information has yet to be provided to Mr. Allen;
12. To further complicate matters, Mr. Allen has suffered from depression dating back to his early years. Upon his incarceration, Mr. Allen was presumably evaluated and medicated by prison medical staff. Up until a visit with Mr. Allen on April 4, 2023, counsel for Mr. Allen found him to be polite, communicative with great eye contact, generally responsive to our questions and exhibiting a good sense of humor on occasion in spite of his false arrest and circumstances. However, Mr. Allen's deteriorating physical condition has been observed by Counsel dating back to the beginning of the new year. As recently as Friday, April 24th, 2023, Attorney Andrew Baldwin met with Mr. Allen with optimistic news about the direction of the case, and Mr. Allen was inquisitive about the information, was thankful about the information and optimistic about the information. Only ten days later (April 3, 2023), Attorneys for Mr. Allen observed a steep decline in Mr. Allen's demeanor, ability to communicate, ability to comprehend and ability to assist in his defense. Simply put, this version of Richard Allen was a very different version than counsel for Mr. Allen had interacted with over the past five months. Mr. Allen appeared to be suffering from various psychotic symptoms which counsel would describe as schizophrenic and delusional. Counsel further believes that in our April 4, 2023 interaction, Mr. Allen seems to be suffering from memory loss and is demonstrating an overall inability to communicate rationally with counsel and family members. Counsel experienced, these symptoms, firsthand, upon visiting Mr. Allen on Monday, April 4th, 2023;