Department of Public Safety
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userystephanieDepartment of Public Safety
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userystephanieState of Missouri, ex inf.
Andrew Bailey, Attorney General
Gregory M. Goodwin
573 751-7017
2522-CC01380
17 (special assignment Judge Ohmer)
Alfred Montgomery
David C. Mason
314 622-4815
St. Louis City Department of Public Safety
St. Louis City Department of Public Safety
815 Olive Street, Suite 200, St. Louis, MO 63101
22nd July 2025 11:30 A
x See Attachment A
Relator
Counsel of Record
Counsel for State of Missouri
Gregory M. Goodwin Shaun J Mackelprang
Chief Counsel, Public Safety Deputy Attorney General
Missouri Bar #65929 Missouri Bar #49627
P.O. Box 899 P.O. Box 899
Jefferson City, MO 65102 Jefferson City, MO 65102
Tel: (573)-751-7017 Tel: (573)-751-0272
Andrew J. Clarke Kate Whitaker
Assistant Attorney General Assistant Attorney General
Missouri Bar #71264 Missouri Bar #76802
P.O. Box 899 P.O. Box 899
Jefferson City, MO 65102 Jefferson City, MO 65102
Tel: (573)-751-1546 Tel: (573)-8795
Gabriela M. Gonzalez Casey Campbell
Assistant Attorney General Assistant Attorney General
Missouri Bar #75576 Missouri Bar #74595
P.O. Box 899 P.O. Box 899
Jefferson City, MO 65102 Jefferson City, MO 65102
Tel: (573)-751-0598 Tel: (573)-751-6623
Caleb Rutledge
Assistant Attorney General
Missouri Bar #74820
P.O. Box 899
Jefferson City, MO 65102
Tel: (573)-751-0812
Counsel for Sheriff Alfred Montgomery
David C. Mason
Missouri Bar #33536
Civil Courts Building
10 North Tucker Blvd 8th Floor
St. Louis, MO 63101
Tel: (314)-622-4815
Matthew J. Ghio
Ghio Law Firm LLC
Missouri Bar #44799
3115 S. Grand, Suite 100
St. Louis, MO 63118
Tel: (314)-622-4815
Justin K. Gelfand
Margulis Gelfand Diruzzo &
Lambson
Missouri Bar #62265
7700 Bonhomme Avenue, Suite 750
St. Louis, MO 63105
Tel: (314)-390-0230
ATTACHMENT A
Under Rule 58.02, Relator requests that the Department of Public Safety
(DPS), the Division of Corrections (DOC), and the St. Louis City Justice Center
(CJC) produce and permit inspection and copying of the designated documents,
records, or tangible items as described further below, that are in its possession,
custody, or control. Any numbered paragraph below that refers to deputies,
officers, employees, or agents of the Sheriff’s Office includes Alfred
Montgomery. Unless otherwise specified, the documents, records, or tangible
items requested concern the time period from January 1, 2025, to the present.
Relator further requests that the custodian of records, where applicable,
produce these documents, records, or tangible items with a business records
affidavit. Rule 58.02(d).
1. All documents that DPS, DOC, or CJC has produced in response
to a subpoena regarding any and all deputies, officers, employees, or agents of
the Office of the Sheriff of the City of St. Louis (Sheriff’s Office) or Sheriff
Alfred Montgomery.
2. All documents and communications, including electronic mail or
messages, exchanged between any officer, employee, or agent of DPS, DOC, or
CJC and any deputy, officer, employee, or agent of the Sheriff’s Office
regarding or related to the Sheriff’s Office’s access to the CJC to interview or
interrogate detainees.
3. All documents and communications, including electronic mail or
messages, exchanged internally between any officer, employee, or agent of the
DPS, DOC, or CJC regarding or related to the Sheriff’s Office’s access to
interview or interrogate detainees.
4. All documents and communications, including electronic mail or
messages, between any officer, employee, or agent of DPS, DOC, or CJC and
any deputy, officer, employee, or agent of the Sheriff’s Office regarding or
related to Alfred Montgomery’s appearance or presence at the CJC on
February 14, 2025.
5. All documents and communications, including electronic mail or
messages, exchanged internally between any officer, employee, or agent of
DPS, DOC, or CJC regarding or related to Alfred Montgomery’s appearance at
the CJC on February 14, 2025.
6. All documents and communications between any officer, employee,
or agent of DPS, DOC, or CJC and any deputy, officer, employee, or agent of
Page 1 of 3
the Sheriff’s Office regarding the Sheriff’s Office’s handcuffing of T R ,
which occurred on February 14, 2025.
7. All documents and communications, including electronic mail or
messages, exchanged internally between any officer, employee, or agent of the
DPS, DOC, or CJC regarding the Sheriff’s Office’s handcuffing of T R ,
which occurred on February 14, 2025.
8. All incident reports or investigative reports concerning the
Sheriff’s Office’s handcuffing of T R , which occurred on February 14,
2025. This request includes any notes or files related to the creation of these
reports.
9. All documents and communications, including electronic mail or
messages, exchanged between any officer, employee, or agent of DPS, DOC, or
CJC and any deputy, officer, employee, or agent of the Sheriff’s Office
regarding or related to Sheriff Alfred Montgomery’s or the Sheriff’s Office’s
control over the corrections side of the CJC (or lack thereof).
10. All documents and communications, including electronic mail or
messages, exchanged internally between any officer, employee, or agent of the
DPS, DOC, or CJC regarding or related to Sheriff Alfred Montgomery’s or the
Sheriff’s Office’s control over the corrections side of the CJC (or lack thereof).
11. All audio and video recordings or camera footage from February
14, 2025, showing Alfred Montgomery in the CJC.
12. All contracts and/or agreements made with the Sheriff’s Office
regarding the transportation of detainees effective from January 1, 2015 to
present.
13. Any documents or communications regarding or related to all
detainee transport requests DPS, DOC, or CJC sent to the Sheriff’s Office that
the Sheriff’s Office fulfilled.
14. Any documents or communications regarding or related to all
detainee transport requests DPS, DOC, or CJC sent to the Sheriff’s Office that
the Sheriff’s Office did not fulfill.
15. All documents, communications, notifications, or correspondence
sent by the CJC to the Sheriff’s Office concerning detainee transportation.
Page 2 of 3
16. All documents and communications in which any officer, employee,
or agent of DPS, DOC, or CJC has stated or represented, in his or her official
capacity, that Alfred Montgomery has lied or failed to state the truth.
17. Any documents or communications regarding or related to all
detainee transport requests received by DPS, DOC, or CJC where the Sheriff’s
Office was copied or notified.
Page 3 of 3
STATE OF ______________ )
) SS
COUNTY OF ____________ )
BUSINESS RECORDS AFFIDAVIT
Before me, the undersigned authority, personally appeared ______________,
who, being by me duly sworn, deposed as follows:
My name is ______________, I am of sound mind, capable of making this
affidavit, and personally acquainted with the facts herein stated:
I am the custodian of the records of ______________________________.
Attached hereto are _____ pages of records from
____________________________________. These _____ pages of records are kept by
___________________________________ in the regular course of business, and it
was the regular course of business of ________________________________ for an
employee or representative of __________________________________________ with
knowledge of the act, event, condition, opinion, or diagnosis recorded to make the
record or to transmit information thereof to be included in such record; and the
record was made at or near the time of the act, event, condition, opinion, or
diagnosis. The records attached hereto are the original or exact duplicates of the
original.
________________________________
Affiant
In witness whereof I have hereunto subscribed my name and affixed my
official seal this ______ day of ___________________, 202__.
________________________________
Notary Public
My Commission expires:________________
