Christopher Reed v. J. Johnson, Superintendent

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -----------------------------------------------------------------X CHRISTOPHER REED, Petitioner, 20-CV-7584 (JLR) (KHP) -against- ORDER J.JOHNSON, Superintendent, Respondent. -----------------------------------------------------------------X KATHARINE H. PARKER, United States Magistrate Judge: Petitioner, currently incarcerated at the Sing Sing Correctional Facility, initiated this action as a petition for writ of habeas corpus. On September 3, 2025, the Court requested a letter from Petitioner’s counsel (Ms. Danielle Von Lehman) in his state court action regarding the status of Petitioner’s CPL § 440.10 motion. (ECF No. 67.) On September 29, 2025, the Court received an email containing Ms. Von Lehman’s letter. The letter is attached to this order as Appendix A. In the letter, Ms. Von Lehman states that she has not yet filed the motion as she was waiting for the prosecution to turn over Petitioner’s case file. On October 8, 2025, the District Attorney filed a letter to the ECF docket (ECF No. 69) indicating, in part, that they have or will turn over the discovery material used at trial “as a courtesy.” (Id. at 2.) The Court agrees with Respondent that there should be no further delay from the date the trial case file is turned over to Ms. Von Lehman and expects it will be turned over within the next 30 days. Accordingly, the Court will permit the stay to continue for another 60 days to allow production of the file and filing of the motion. If the updated CPL § 440.10 motion is not filed within the next 60 days, this Court will lift the stay and proceed with resolving the habeas petition. If the motion is filed, Petitioner may request an extension of the stay in this action so long as that request is received by December 8, 2025. Either way, the parties shall file a status update by December 8, 2025, which shall include their positions on lifting or extending the stay notwithstanding any pending motion under CPL § 440. The Clerk of Court is kindly requested to mail this order to the Petitioner. The Respondent is respectfully requested to serve this letter upon Ms. Von Lehman by overnight mail on or before October 13, 2025. SO ORDERED. DATED: New York, New York October 9, 2025 ue Uthaine H fake KATHARINE H. PARKER United States Magistrate Judge APPENDIX A NEW(3 Y47O)R2K54, -N0Y83 110007 DVLesq.ny@Gmail.com September 26, 2025 VIA ECF Honorable Katharine H. Parker United Stated Magistrate Judge Southern District of New York 500 Pearl Street, Courtroom 17D New York NY 10007-1312 Re: Christopher Reed v. Johnson, Case No. 20CV-7584 (JLR) (KHP) Your Honor: I, alongside Matthew Christiana, have been appointed to represent Mr. Christopher Reed in the current New York State post-conviction proceeding. In accordance with Your Honor’s Order, dated September 3, 2025 (ECF No. 67), I am writing to provide you with a status update regarding Mr. Reed’s pending CPL § 440.10 Motion (“440 Motion”). Mr. Reed’s CPL 440 motion seeks vacatur of his conviction on multiple constitutional grounds, including ineffective assistance of counsel in violation of the Sixth Amendment and misconduct in violation of Brady v. Maryland. While the motion is substantially prepared and nearly final, resolution of certain claims requires a determination of what documents and information were in trial counsel’s possession at the time of trial. Unfortunately, trial counsel resides outside of the country, and despite diligent efforts, I have been unable to establish contact. Accordingly, I have undertaken repeated efforts to obtain the prosecution’s trial file. These efforts have included direct communications with the assigned prosecutor as well as formal FOIL requests to the Bronx District Attorney’s Office. As outlined in the appended, February 2025, I submitted a FOIL request to the DA’s office. After months of delay—and a constructive denial appeal—the DA finally responded on May 13, 2025, advising that the materials must be requested directly from ADA Won and the Bronx Exhibit Coordinator. The next day, I followed that directive and submitted requests to both ADA Won and the Bronx Exhibit Coordinator. Despite multiple follow-ups, the requested file has still not been produced. Most recently, on September 26, 2025, ADA Won informed me that a paralegal will begin reviewing the file at the end of next week. Upon receipt of the prosecution’s trial file, I will promptly finalize and file Mr. Reed’s CPL 440 motion. Should the Bronx District Attorney’s Office produce the file within the next several weeks, I anticipate being in a position to submit the motion on or about December 2025. I remain available to provide any additional information the Court may require and thank the Court for its attention to this matter. Respectfully Submitted, /s/ Danielle Von Lehman Danielle Von Lehman, esq. SSSSuuuubbbbjjjjeeeecccctttt:::: FOIL Request - People v. Christopher Reed; Ind. No. 12-2082 DDDDaaaatttteeee:::: Wednesday, February 26, 2025 at 12:08:35 PM Eastern Standard Time FFFFrrrroooommmm:::: Matthew Christiana TTTToooo:::: foilrequest@bronxda.nyc.gov AAAAttttttttaaaacccchhhhmmmmeeeennnnttttssss::::FOIL request re Bx Ind. 12-2082.pdf Good afternoon, Please find the attached request for records. As you know, N.Y. Pub. Off. Law § 89 (3)(a) requires an agency to respond to written FOIL requests within five (5) business days of receipt. Therefore, I would appreciate a response as soon as possible, and look forward to hearing from you shortly. Thank you. Kind regards, Matt Christiana -- Matthew Christiana Kopke Christiana & Rastetter LLP 199 Cook Street, Suite 308 Brooklyn, NY 11206 t: (917) 451-9525 f: (347) 315-9815 kcrllp.com Freedom of Information Law Officer Office of the Bronx County District Attorney 198 East 161 Street Bronx, New York 10451 FOIL Unit, 10 Floor (718) 838-7107 Via email: foilrequest@bronxda.nyc.gov Re: People v. Christopher Reed; Ind. No. 12-2082 To Whom It May Concern: As Mr. Christopher Reed’s appointed counsel and in accordance with Brady v. Maryland, 373 US. 83 (1963) and the New York Freedom of Information Law (McKinney’s Public Officers Law § 84), I respectfully request that you forward us a complete copy of the District Attorney’s prosecution file in the above referenced matter. This request includes, but is not limited to: e Phone records pertaining to: o Katherine Urena; o Christopher Reed e Any and all witness statements; e Any and all notes compiled and created by the Bronx District Attorney’s Office e Any and all photographs; e DA summaries/write-ups; e Any and all files retained by the Bronx District Attorney’s Office relating to the credibility or misconduct of the following NYPD officers from the 46" Precinct: o Lt. Paul McMahon (Tax ID: 899574; o Det. Terence Munnelly (Tax ID: 916925) I would appreciate your prompt reply to this request. Best Regards, Matthew W. Christiana, Esq. Matt@kcrllp.com Brooklyn, NY 11206 t/f: (917) 451-9525 e: office@kcrllp.com April 29, 2025 VIA EMAIL Bronx District Attorney’s Office foilrequest@bronxda.nyc.gov Re: FOIL request for case and arrest records for Christopher Reed (Ind. No. 12-2082) To Whom It May Concern: I hereby appeal the constructive denial of my FOIL request, dated January 23, 2024, and annexed hereto as Exhibit A. The Bronx DA’s officer responded that same day and indicated I would receive a response within 60 business days. Said response is annexed hereto as Exhibit B. Over 60 days has now passed and I have not heard anything regarding my FOIL request. Thus, this constructive denial appeal follows. An agency’s unreasonable delay in providing responsive records constitutes a constructive denial of a FOIL request. See FOIL § 89(3)(a); Murray v. Matusiak, 247 A.D.2d 303 (1st Dept. 1998); Empire Ctr. For Pub. Policy, Inc. v. New York City Office of Payroll Admin., 54 Misc. 3d 121 1(A) (Sup. Ct. N.Y. County 2017). As of the date of this letter, the Bronx DA’s office has had over the period of time requested to formally respond to the FOIL request. As the Honorable Arlene Bluth recently opined, “[a FOIL] petitioner should not have to wait indefinitely while respondent ignores [the petitioner’s] requests.” See Rickner PLLC v. City of New York et al, Index No. 1578782021 (Sup. Ct. N.Y. Co., October 5, 2021) (ordering FOIL respondent to make a determination on each of petitioner’s FOIL requests and granting attorney’s fees) (annexed hereto as Exhibit C). As required by the Freedom of Information Law, the head or governing body of an agency, or whomever is designated to determine appeals, is required to respond within 10 business days of the receipt of an appeal. If the records are denied on appeal, please explain the reasons for the denial fully in writing as required by law. In addition, please be advised that the Freedom of Information Law directs that all appeals and the determinations that follow by sent to the Committee on Open Government, Department of State, One Commerce Plaza, 99 Washington Ave., Albany, New York 12231. If feasible, please release these records electronically to matt@kcrllp.com. If there are any costs associated with this request, please do not hesitate to contact me at the same address for payment. Page 1 of 2 Sincerely, Wt / 2 tots: Matthew Christiana Page 2 of 2 DCATLIDIL A Freedom of Information Law Officer Office of the Bronx County District Attorney 198 East 161 Street Bronx, New York 10451 FOIL Unit, 10 Floor (718) 838-7107 Via email: foilrequest@bronxda.nyc.gov Re: People v. Christopher Reed; Ind. No. 12-2082 To Whom It May Concern: As Mr. Christopher Reed’s appointed counsel and in accordance with Brady v. Maryland, 373 US. 83 (1963) and the New York Freedom of Information Law (McKinney’s Public Officers Law § 84), I respectfully request that you forward us a complete copy of the District Attorney’s prosecution file in the above referenced matter. This request includes, but is not limited to: e Phone records pertaining to: o Katherine Urena; o Christopher Reed e Any and all witness statements; e Any and all notes compiled and created by the Bronx District Attorney’s Office e Any and all photographs; e DA summaries/write-ups; e Any and all files retained by the Bronx District Attorney’s Office relating to the credibility or misconduct of the following NYPD officers from the 46" Precinct: o Lt. Paul McMahon (Tax ID: 899574; o Det. Terence Munnelly (Tax ID: 916925) I would appreciate your prompt reply to this request. Best Regards, Matthew W. Christiana, Esq. Matt@kcrllp.com SSuubbjjeecctt:: FOIL Request DDaattee:: Thursday, January 23, 2025 at 9:09:02 AM Eastern Standard Time FFrroomm:: FOILREQUEST (BronxDA) TToo:: Matthew Christiana The Bronx County District Attorney’s Office has received your request for records pursuant to New York Public Officers Law, Article 6, §§84, et seq., also known as the Freedom of Information Law (“FOIL”). If you have provided us with the information necessary to process a request, our Office will initiate the process of locating responsive records. You can expect a determination or update in approximately 60 business days. If we fail to render a determination or provide you with an update within that time frame, please do not hesitate to contact us. Alternatively, you may appeal a “constructive denial” upon the expiration of 60 business days by writing to: FOIL Appeals Officer Peter Coddington, Bronx County District Attorney’s Office, 198 East 161st Street, Bronx, NY 10451. If you have not provided sufficient information, our Office will inform you as soon as possible and let you know what additional information we require to process your request. For disclosure of physical copies of records, this Office charges a $0.25 per page; $0.50 per color copy; $5.00 per audio CD; and $15.00 per video DVD copying fee. There is no provision in the Public Officers Law for a waiver of this fee. See Whitehead v. Morgenthau, 146 Misc.2d 806, 807-08 (N.Y. Cty. 1990). Alternatively, there is no charge if the records are delivered electronically by e-mail or on OneDrive. Please note that if you are requesting files for the purpose of litigation, your request will nevertheless be processed in the order in which it was received. If time is of the essence, it may behoove you to obtain a subpoena signed by the judge presiding over your civil matter. Thank you for your request and we hope to be of service to you. ednistsiteym toin wahtioonm o itr hcaosp ybinege no fa tdhdisre esmseadil. isIf sytoriuc talyr ep rnooht ibthitee din. tIef nydoeud h raevceip rieencet,i vyeodu tahries heemraeibl yin n eortrifoier,d p tlheaats eany delete it and notify the sender by return email. KDISTRICS Kan Wao [heal | is OFFICE OF THE BRONX DISTRICT ATTORNEY DARCEL D. CLARK 198 East 161 Street (718) 590-2000 District Attorney Bronx, New York 10451 (718) 590-6419 - Fax http://bronxda.nyc.gov PETER D.C ODDINGTON FOIL Appeals Officer” May 13, 2025 VIA ELECTRONIC MAIL Matthew Christiana, Esq. Kopke Christiana & Rastetter LLP 199 Cook Street, Suite 308 Brooklyn, NY 11206 matt@kerllp.com Re: | FOIL Appeal Determination People v. Christopher Reed Indictment Number 282-2012 Dear Mr. Christiana: This letter responds to your appeal dated April 29, 2025, under the Freedom of Information Law (“FOIL”), alleging that this Office constructively denied your FOIL request. For the reasons set forth below, I find that this Office did not constructively deny your FOIL request. Upon further review of this matter, however, I am constrained to deny your request because there is litigation pending relating to the underlying criminal prosecution. Following a trial in Supreme Court, Bronx County, Christopher Reed was convicted of first-degree manslaughter and sentenced to 25 years of incarceration. In 2020, Mr. Reed filed pro se a petition for a writ of habeas corpus in federal court in the Southern District of New York under Case Number 20CV07584. That same year, the federal court stayed the habeas corpus proceedings for Mr. Reed to exhaust his state court remedies. In February 2021, Mr. Reed filed pro se a motion in Supreme Court, Bronx County, to set aside the judgment of conviction pursuant to CPL §440.10. Thereafter, Supreme Court, Bronx County, appointed counsel to represent Mr. Reed. In 2024, Supreme Court, Bronx County, stayed the motion to set aside the verdict while new counsel, Danielle Von Lehman, Esq., determined how to proceed. It is my understanding that you are working with Ms. Lehman on the motion, and that Ms. Lehman has contacted the ADA assigned to these matters, T. Charles Won, to obtain records in connection with this matter. With respect to your FOIL appeal, our records indicate that on February 26, 2025, you submitted a FOIL request for “a complete copy of the District Attorney’s prosecution file” in People v. Christopher Reed, Indictment Number 282-2012, as well as “[a]ny and all files” maintained by this Office “relating to the credibility or misconduct” of Lt. Paul McMahon and May 13, 2025 Page 2 of 2 Detective Terence Munelly. When your request was submitted, this Office advised you to “expect a determination or update in approximately 60 business days,” or by May 16, 2025. In your FOIL appeal, you claim that your FOIL request is dated January 23, 2025, and therefore your request was constructively denied. However, your FOIL request is, in fact, undated. In support of your claim that you submitted the request on January 23, 2025, you attached this Office’s email purporting to acknowledge your FOIL request regarding Mr. Reed. That email, however, was sent to you in connection with a different FOIL request you submitted to this Office for records relating to the prosecution of Nathaniel Geebro. Notably, that request was fulfilled on April 4, 2025. Accordingly, there has been no constructive denial of your request pertaining to Christopher Reed. As there is pending litigation regarding this matter, however, I am constrained to deny your FOIL request because disclosure of the requested records would interfere with pending judicial proceedings. See Pub. Off. L. §87(2)(e)(i); Lesher v. Hynes, 19 N.Y.3d 57 , 6768 (2012); Matter of Pittari v. Pirro, 258 A.D.2d 202 , 203-04 (2d Dept. 1999), lv. denied, 94 N.Y.2d 755 (1999) (where a criminal proceeding is pending, documents are exempt under Pub. Off. L. §87(2)(e)(i) upon a “generic determination” that disclosure of categories of records would create broad risks of harm; a document-by-document showing of interference is not required). The First Department has even held that documents were properly withheld based on a representation that FOIL "disclosure . . . . would interfere with . . . [the] handling of the appeal of the criminal conviction." Matter of Sideri v. District Attorney of New York County, 243 A.D.2d 423, 423 (1st Dept. 1997) (emphasis added). To the extent that you seek records from the criminal prosecution in connection with the post-conviction litigation, you should contact ADA Won at wonc@bronxda.nyc.gov. Alternatively, you may contact the Appeals Bureau of this Office at BxExhibitCoordinator@Bronxda.nyc.gov, and send a copy of your message to ADA Won. Very truly yours, /s/ Peter D. Coddington FOIL APPEALS OFFICER cc: coog@dos.ny.gov (via email) NYS Committee on Open Government Department of State One Commerce Plaza 99 Washington Avenue, Suite 650 Albany, NY 12231 SSSSuuuubbbbjjjjeeeecccctttt:::: RE: [EXTERNAL] Records - People v. Christopher Reed. Ind. No. 12-2082. DDDDaaaatttteeee:::: Friday, September 26, 2025 at 12:08:58 PM Eastern Daylight Time FFFFrrrroooommmm:::: Won, Charles-Tae Hoon (BronxDA) TTTToooo:::: dvlesq.ny CCCCCCCC:::: Matthew Christiana AAAAttttttttaaaacccchhhhmmmmeeeennnnttttssss::::image001.png Hello, The paralegal who was reviewing the discovery material left the o\ice. So, I need to ask a new paralegal to finish reviewing the material, which I believe, is fairly lengthy. As the paralegal is busy preparing briefs for next week’s Appellate Division filing deadline, she likely won’t be able to start reviewing until end of next week. We’ll try our best to finish the review soon as possible. Thank you, T. Charles Won Assistant District Attorney Bronx County District Attorney’s O\ice Appeals Bureau 198 E. 161st Street Bronx, NY 10451 (718) 838-7097 wonc@bronxda.nyc.gov FFFFrrrroooommmm:::: Danielle Von Lehman <dvlesq.ny@gmail.com> SSSSeeeennnntttt:::: Monday, September 15, 2025 8:00 AM TTTToooo:::: Won, Charles-Tae Hoon (BronxDA) <WONC@bronxda.nyc.gov> CCCCcccc:::: MaRhew ChrisTana <maR@kcrllp.com>; BxExhibitCoordinator (BronxDA) <BxExhibitCoordinator@Bronxda.nyc.gov> SSSSuuuubbbbjjjjeeeecccctttt:::: Re: [EXTERNAL] Records - People v. Christopher Reed. Ind. No. 12-2082. Good afternoon ADA Won, I am in receipt of the letter from SDNY requesting an update by September 30, 2025. We are awaiting a status update on the trial file that your o\ice is reviewing. I believe we will be ready to file soon after we have the opportunity to review the materials turned over to the defense attorney as pre-trial discovery. Do you have a sense of when we can review those materials? Thank you, (347) 254-0831 New York, NY On Thu, Aug 21, 2025 at 2:38 PM Won, Charles-Tae Hoon (BronxDA) <WONC@bronxda.nyc.gov> wrote: Hello, The Bronx District Attorney’s O\ice Exhibits Coordinator is in receipt of your request for documents pertaining to the case People v. Christopher Reed, Ind. No. 282/2012. Although this O\ice has no statutory discovery obligation post-conviction, as a courtesy in this case, we will disclose documents that we believe were turned over to the defense as part of the pre-trial discovery. We are right now in the process of reviewing the file. We will strive to have the documents ready for disclosure soon as possible. Thank you, T. Charles Won Assistant District Attorney Bronx County District Attorney’s O\ice Appeals Bureau 198 E. 161st Street Bronx, NY 10451 (718) 838-7097 wonc@bronxda.nyc.gov FFFFrrrroooommmm:::: MaRhew ChrisTana <maR@kcrllp.com> SSSSeeeennnntttt:::: Tuesday, August 19, 2025 7:10 PM TTTToooo:::: BxExhibitCoordinator (BronxDA) <BxExhibitCoordinator@Bronxda.nyc.gov> CCCCcccc:::: dvlesq.ny <dvlesq.ny@gmail.com> SSSSuuuubbbbjjjjeeeecccctttt:::: Re: [EXTERNAL] Records - People v. Christopher Reed. Ind. No. 12-2082. Good evening, I am once again circling back on this. We have been attempting to obtain the requested materials for months. Please indicate, unequivocally, whether the Bronx DA will produce the requested file, or alternatively, if it is refusing to do so. Kind regards, Matt Christiana -- Matthew Christiana Bt:r (o9o1k7l)y 4n5, 1N-9Y5 1215206 f: (347) 315-9815 kcrllp.com FFFFrrrroooommmm:::: Matthew Christiana <matt@kcrllp.com> DDDDaaaatttteeee:::: Thursday, August 7, 2025 at 10:47 AM TTTToooo:::: BxExhibitCoordinator (BronxDA) <BxExhibitCoordinator@Bronxda.nyc.gov> CCCCcccc:::: Danielle Von Lehman <dvlesq.ny@gmail.com> SSSSuuuubbbbjjjjeeeecccctttt:::: Re: [EXTERNAL] Records - People v. Christopher Reed. Ind. No. 12-2082. Good morning, I am once again circling back on this. Please indicate whether the Bronx DA will produce the requested file. Kind regards, Matt Christiana -- Matthew Christiana Kopke Christiana & Rastetter LLP 199 Cook Street, Suite 308 Brooklyn, NY 11206 t: (917) 451-9525 f: (347) 315-9815 kcrllp.com FFFFrrrroooommmm:::: Matthew Christiana <matt@kcrllp.com> DDDDaaaatttteeee:::: Monday, July 21, 2025 at 4:54 PM TTTToooo:::: BxExhibitCoordinator (BronxDA) <BxExhibitCoordinator@Bronxda.nyc.gov> CCCCcccc:::: Danielle Von Lehman <dvlesq.ny@gmail.com> SSSSuuuubbbbjjjjeeeecccctttt:::: Re: [EXTERNAL] Records - People v. Christopher Reed. Ind. No. 12-2082. Good afternoon, We did submit a FOIL request on this case already. However, we were instructed to direct our request to you. Please see the attached. As you know, this case is in active post-conviction litigation, and Mr. Reed is entitled to the documents we have requested. As such, your office is required to provide Mr. Reed with the requested information. To the extent you are refusing to produce these items, please indicate so clearly so that we have a clear record of the Bronx DA’s refusal for use in future Alternatively, to save time and expense for all involved, please indicate whether the Bronx DA will produce the requested file—especially considering on May 30, 2025, you represented that you were awaiting the file and would provide us with updates once it was received. I look forward to your response. Best regards, Matthew Christiana Kopke Christiana & Rastetter LLP 199 Cook Street, Suite 308 Brooklyn, NY 11206 t: (917) 451-9525 f: (347) 315-9815 kerllp.com From: BxExhibitCoordinator (BronxDA) <BxExhibitCoordinator@Bronxda.nyc.gov> Date: Monday, July 21, 2025 at 4:43 PM To: Matthew Christiana <matt@kcrllp.com> Subject: RE: [EXTERNAL] Records - People v. Christopher Reed. Ind. No. 12-2082. Good Afternoon Mr. Christiana, It is to our Knowledge that a 440 motion and a habeas has already been filed for this case. For any further request please reach out to foilrequest@bronxda.nyc.gov Shyah Joseph Appellate Litigation Paralegal Appeals Bureau District Attorney’s Office, Bronx County 260 E. 161°" Street Bronx, New York 10451 Josephshy@bronxda.nyc. gov (718) 838-7649. ext 2401 UL “A. ae) From: Matthew Christiana <matt@kcrllp.com> Sent: Friday, July 4, 2025 2:15 PM To: BxExhibitCoordinator (BronxDA) <BxExhibitCoordinator@Bronxda.nyc.gov> Cc: dvlesq.ny <dvlesq.ny@gmail.com> Subject: Re: [EXTERNAL] Records - People v. Christopher Reed. Ind. No. 12-2082. Good afternoon, I hope this email finds you well. Circling back on this. Any updates are greatly appreciated. Kind regards, Matt Christiana Matthew Christiana Kopke Christiana & Rastetter LLP 199 Cook Street, Suite 308 Brooklyn, NY 11206 t: (917) 451-9525 f: (347) 315-9815 kerllp.com From: BxExhibitCoordinator (BronxDA) <BxExhibitCoordinator@Bronxda.nyc.gov> Date: Friday, May 30, 2025 at 10:24 AM To: Matthew Christiana <matt@kcrllp.com> Subject: RE: [EXTERNAL] Records - People v. Christopher Reed. Ind. No. 12-2082. Good Morning, | have requested the trial box/folder for this case to fulfill this request on 5/19/25. However, I have not rec’d it yet or any follow up. Once | have one, | will update you as soon as I can. Thank you, Shyah Joseph Appellate Litigation Paralegal Appeals Bureau District Attorney’s Office, Bronx County 260 E. 161° Street Bronx, New York 10451 Josephshy@bronxda.nyc. gov (718) 838-7649. ext 2401 “A. ae Oe FFFFrrrroooommmm:::: MaRhew ChrisTana <maR@kcrllp.com> SSSSeeeennnntttt:::: Wednesday, May 28, 2025 7:42 PM TTTToooo:::: BxExhibitCoordinator (BronxDA) <BxExhibitCoordinator@Bronxda.nyc.gov> CCCCcccc:::: dvlesq.ny <dvlesq.ny@gmail.com> SSSSuuuubbbbjjjjeeeecccctttt:::: Re: [EXTERNAL] Records - People v. Christopher Reed. Ind. No. 12-2082. You don't often get email from matt@kcrllp.com. Learn why this is important Good evening, I hope this email finds you well. I am writing to circle back on the below. Any insight on expected timeline is greatly appreciated. Kind regards, -- Matthew Christiana Kopke Christiana & Rastetter LLP 199 Cook Street, Suite 308 Brooklyn, NY 11206 t: (917) 451-9525 f: (347) 315-9815 kcrllp.com FFFFrrrroooommmm:::: Matthew Christiana <matt@kcrllp.com> DDDDaaaatttteeee:::: Monday, May 19, 2025 at 2:32 PM TTTToooo:::: BxExhibitCoordinator (BronxDA) <BxExhibitCoordinator@Bronxda.nyc.gov> CCCCcccc:::: dvlesq.ny <dvlesq.ny@gmail.com> SSSSuuuubbbbjjjjeeeecccctttt:::: Re: [EXTERNAL] Records - People v. Christopher Reed. Ind. No. 12-2082. Good afternoon, Thank you for your email. Please find the below list: 1 – phone records subpoenaed by the NYPD/Bronx DA’s office for both Katherine Urena and Christopher Reed, under phone numbers: 347-499-2989; 347-904-1849; 347-7378781, along with records relating to any other numbers for which a subpoena was sent; 2 – All witness statements obtained by the NYPD/Prosecution, including but not limited to, any statements provided by Katherine Urena; 3 – Any other notes created/retained by the Bronx DA’s office regarding items (1) and (2) not otherwise subject to work-product privilege 4 – A photograph of Christopher Reed following his arrest; 5 - Any and all disciplinary/Garret/Brady files pertaining to Lt. Paul McMahon (Tax ID: 899574) and Det. Terrence Munnelly (Tax ID: 916925). Please let me know if any additional information or clarification is needed. Thank you again, -- Matthew Christiana Kopke Christiana & Rastetter LLP 199 Cook Street, Suite 308 Brooklyn, NY 11206 t: (917) 451-9525 f: (347) 315-9815 kcrllp.com FFFFrrrroooommmm:::: BxExhibitCoordinator (BronxDA) <BxExhibitCoordinator@Bronxda.nyc.gov> DDDDaaaatttteeee:::: Monday, May 19, 2025 at 1:07 PM TTTToooo:::: Matthew Christiana <matt@kcrllp.com> SSSSuuuubbbbjjjjeeeecccctttt:::: RE: [EXTERNAL] Records - People v. Christopher Reed. Ind. No. 12-2082. Hi Mr. ChrisTana, We have received your request regarding this maRer. Can you compile a list of specifically what you are requesTng for example Exhibit 1, 2, 3 ? If possible ? Thank you, FFFFrrrroooommmm:::: MaRhew ChrisTana <maR@kcrllp.com> SSSSeeeennnntttt:::: Wednesday, May 14, 2025 10:26 AM TTTToooo:::: BxExhibitCoordinator (BronxDA) <BxExhibitCoordinator@Bronxda.nyc.gov> CCCCcccc:::: dvlesq.ny <dvlesq.ny@gmail.com> SSSSuuuubbbbjjjjeeeecccctttt:::: [EXTERNAL] Records - People v. Christopher Reed. Ind. No. 12-2082. You don't often get email from matt@kcrllp.com. Learn why this is important CCCCAAAAUUUUTTTTIIIIOOOONNNN!!!! EEEEXXXXTTTTEEEERRRRNNNNAAAALLLL SSSSEEEENNNNDDDDEEEERRRR.... Never click on links or open attachments if sender is unknown, and never provide user ID or password. If ssssuuuussssppppiiiicccciiiioooouuuussss, report this email by hitting the PPPPhhhhiiiisssshhhh AAAAlllleeeerrrrtttt BBBBuuuuRRRRoooonnnn. If the button is unavailable or you are on a mobile device, forward as an attachment to phish@oti.nyc.gov. Good morning, Please find an attached request seeking records pertaining to People v. Christopher Reed. Ind. No. 12-2082. Best regards, Matthew Christiana -- Matthew Christiana Kopke Christiana & Rastetter LLP 199 Cook Street, Suite 308 Brooklyn, NY 11206 t: (917) 451-9525 f: (347) 315-9815 kcrllp.com This email communication and any files transmitted with it contain privileged and confidential information from the Bronx County District Attorney's Office and are intended solely for the use of the individuals or entity to whom it has been addressed. If you are not the intended recipient, you are hereby notified that any dissemination or copying of this email is strictly prohibited. If you have received this email in error, please delete it and notify the sender by return email.