Destwicr Arroaney ‘QUEENS COUNTY Richard A. Brown, ‘tne erg Niowember 12, 2000 Horurle Jaime A. Rios Supreme Court, Queens County 125-01 Queens Boulevard Kew Garclens, Naw Yor 11415 Re: People vs. Tyrone Jakrson incictavent Na. 2002-2000 Dear Justice Rios: On Jun Aingreeallempdreabery scomcied, fier jury tral, of murder in the second ne sever degre, item ple: Kidss 9p 7g inthe scene deste” and ctimina’ possession ofa weapon in the second ad thitd deat of Lerey Vann dusing a failed robbery atempt ‘Thedefendant has now moved to vacate the judgment of conviction based. in parton wom ‘vatervents given nast conviction 19a defers investigator ay tree indivieas fica sta:omeat ie from Elenry Hanley, whe had testified for the prosecution at trial th hewasam cyowitress io the shooting, He iisntifie’ heccfendant, sshom he claimed chad known for anumbe: of years, as one of to people involved inthe vobivery and murder. Mr. Hanley's wil testimony was consistent with prior statements that he had given to detectives, 2 vidsotaped Siaterent that he had giver to an Assistant Disinc: Attorney and his grsnd jury testimony. in his post-conviction statement, Tianley recants his trial testimony enfizely, although in suasequert aterroats to our effice hs has sinoe recsstod his resentation. ‘The sceond postconviction statement by the defense is that of Shanese Knigh:, Eaniey’saurt, who resided inthe apartmert ahove that eecupied by Mr. Wanley. Mis. Knight says :hat she witnessed the shooting and saw a ran other thar the decendzat shoot Vana. Her statement is, however, incensistet with a statement that she gave to detectives to days afer the shooting in wien she claimed nc! tn hive seen the staotiny Ms. Krighs albu stale i her post-coowietien statement that Flanley could sot have seen the shocting because he was downstairs asleep in his partment atthe time. ‘The third statersent is that of Charmaine Ramdass, the mother of Hanley’ stwo-year old son Ms: Ramen, her pst trial stoleaut-els stat Me-anley wssleesingnast 9 her tthe me of the shooting and coulé no: have seen whs: took place. That stateenl, as well as the saiterient ef Ms Krvght m which she also elsims shat Kanles was asleep in is apartescnt at she tive ofthe shooting, coatradic's the testinoay of Stanley Gask.ns, adelense ab witness, ia elaimee ra have Freon playing vieo games with Hensy Taney at tke time of the shocting review ing te fact in preparctioa forts eating fiat yor cudeied be held regan yont-comistian salement= > tag come to my etenton that & tral cur tral assstan: stated, in resporse io the Court's nguiry, that te did not have any knowledge asta ‘he wh Knights fr luc, weve, fonreays esTisrtheassistan: hac mt wth Ms, Knight a ier glac= ol employment. Trot fit shovld have been ciselesed, The lure te do so "vzs totaly inconsistent with the high ethical siasdatds the: L expect tom ry sssislan snd 1 uv, aa result reeted shat 3 thezeugh intemal :aquiry af she failure to discloce thst fist be had. Ane if dicciplinary action agavnst te w her with tw detectives frommyettice, ca appa, + will Bo takes While te failure te disclose the infrmatine shou she whereabouts cf Ms. Knig’t may nos, inthe end, Fave hac any impact oa the ou:cosre of the ial the eoncuet whic occurred cart 8 ceomdonell ccontirsy. se ore prepared can far tothe y2cccurcf the defendant's corvietion and tothe grant trial st which tre defendar: wil aves full and la pe-tiniy! any ond all wnesscs who he ehaoses to have in addition, ard in evde> to ns onlience an the putietal process, we will, prior (9 anv rexral, conduct 2 comprehensive re- amination of every aspect ofthis case oo se io be seta thal ne prosecution of she dsterlant 5 justffed Yours septal eH Richa A Fre, Distic: Agauney b Honorable Steven WY. Tisher Nlan ". Brenmsr Fs a2