2002 11NOV 12 DA Brown's Ltr to JSC Rios

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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