Davenport Supplimentary Motion For New Detention Hearinger

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND UNITED STATES OF AMERICA v.

WDQ 09-183

DIETRA DAVENPORT MEMORANDUM IN SUPPORT OF MOTION FOR RECONSIDERATION OF DETENTION STATUS Background Ms. Davenport has worked for 20 years with the same company, raised two children, purchased a home, lived a life outside the criminal milieu and is well respected by those who know her. Her employer in the email set out below says eloquently how different she is from the normal set of defendants that appear before this Court: Dear Mr. Saunders: Per your request, I am writing to provide my personal and professional comments as they relate to Dietra Davenport and your efforts to have her relocated from incarceration in Washington, DC to a half-way facility in Baltimore. As you are aware, Ms. Davenport has been an employee of The Joseph E. Shaner Co. for nearly 20 years. We consider her to be a valuable part of our "family." Ms. Davenport has always been a loyal and dedicated employee who has willingly taken on new responsibilities and who is always available to assist others with special projects or needs. In addition to her regular daily administrative responsibilities, Ms. Davenport also directly serves one or two of our smaller client associations and has been instrumental to them in keeping them organized and addressing the needs of their members. At no

time during her employment with us have we ever felt anything other than great affection and pride in having Ms. Davenport on our staff. Needless to say, we are all devastated by the recent events which have led to Ms. Davenport’s incarceration. We firmly believe that Ms. Davenport was naive and was misled by Eric Brown. Personally, we have watched Ms. Davenport raise two well-disciplined children. The oldest, Martasia, was just born when Ms. Davenport joined our firm. Only three months ago, we added Martasia to our staff. Ms. Davenport’s son, Dante, was born while she was working with us. I’ve been delighted to watch how Dietra has sternly, but lovingly, raised her children and how she’s managed to keep them off the streets in a community where others have failed in this challenge. She is a mother that any child would be proud to call "mom". I’m not sure what else I can add that will help you in your efforts. As we discussed, it hurt me deeply to have to have filled Dietra’s job here, but it had to be done. When the present situation is finally resolved (in what I can only pray will be to Dietra’s favor), I will do everything I can to assist her in finding new employment. If I may be of any further assistance, please feel free to call upon me. Thomas C. Shaner, CAE

The Black Book It would be easy for a person to view the "Black Book" as a naïve political statement meant to learn from the mistakes of criminal experience and jail time with the intent to further oneself within his community through political action. It is interesting to note initially that the book is endorsed by Dr. Audrey Bundley, Leslie Parker Blyther, Professor Anne Arundel Community College, Tyrone Powers, PhD, Institute for Criminal Justice,

Bridget Smith, Executive Director of Partners in Progress, and Mike Jones, author of Black Son Rising. A quick Internet search of, for example, Tyrone Powers shows that he was a past member of the Baltimore City Police Department and the FBI. He was also a speaker at a conference held by the Department of Juvenile Justice in 2005 at the Anne Arundel Community College along with Kenneth C. Montague Jr., Secretary,Department of Juvenile Services.

Dr. Powers states as follows in his endorsement: These are difficult days that require concrete, specific, effective solutions. This book provides that and more. If we want to win, to change our condition, our situation and the life chances of this generation, of our children and of our children's children then we must read, analyze, think, learn and apply the lessons, concepts and practical solutions that are a part of this extraordinary volume written by four extraordinary insightful men and leaders.1

In its preface the book describes itself as a "changing lifestyles living policy book." The book goes out of its way to describe itself as appealing to a political organization and not a gang. The book references the gang mentality as "the backdrop to the chaos that we face in our neighborhoods."

1 Ms. Davenport's husband, Eric Brown, is one of the authors of this book.

In the first few pages it starts off as follows: To all gang members throughout the state please heed our warning, put your gats down and pull your pants up. Learn to love yourself and your people, try being a Black man instead of a big boy get yourself some morals and principles and get rid of that half slip Bush an attitude that you display which is only an imitation of the buffoon to see on... B. E. T.... This struggle within that I'm speaking of is the one between being a conscious Black man or being a gangster.

There is nothing on the face of this book that would in anyway lead the ordinary reader to believe that this book was being used in the manner that the Government describes that Mr. Brown was using it, to guide and control a violent gang both inside and outside of the prisons in Maryland. Indeed, the Government at the prior detention hearing noted that Mr. Brown chastised Mr. Davenport for reading certain correspondence intended for him (clearly showing an intent to keep her in the dark about his illegal purposes). That is in startling contrast to his other conversations, for example with Rainbow, clearly setting out his intent. s/ Thomas J. Saunders Federal Bar # 25084 3600 Clipper Mill Road, Suite 201 Baltimore, MD 410-662-5586 [email protected] cc:

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