The response filed by the government was not filed by the deadline of 7/28. The deadline passed and the government filed on 7/29 a request for an extension, this extension also had a date of October 29 as the day that it had originally been due? It is July so the paperwork was obviously very much rushed and to ask for an extension typically, you would have to do that before the deadline passes, but just filing a late comes into play with some of the arguments. The judge accepted their late request for an extension and they submitted a response on that same day of 7/29…

Scare tactics 

The US attorney used scare tactics and language that was specifically geared to make people fear what would happen if Michael was released. They continue to mention throughout the description, crimes of violence. The specific act of being responsible for somebody’s death does not lay solely on Michael, there was no evidence for a conviction that he ever was the one who directly caused somebody’s death. In fact, they even mention mr culp in their rundown of events, Mr. Culp sadly passed during a robbery that occurred. They had tried to place this robbery on Michael as well but before jury was even selected the judge realized that Michael was in police custody the day of Mr. Culps robbery and death. The US attorney claims that they are doing this for public safety however, the four other men who were involved in the exact same crimes with Michael are all free walking today because they cooperated and took deals. Those men that were responsible for Mr. Culps death are free. Michael is being punished for practicing his constitutional right to stay silent.  The codefendants, all in their 20s, sacrificed a minor for their freedom.

The crimes charged are not the same as the crimes he was convicted of, however their counter continues to mention the shootings even going as far as to call him a cold blooded murderer. Again the jury did not convict Michael because they had no evidence. 
The US attorney continues to highlight violence however I am having a hard time understanding because by their logic they have let four other dangerous, violent men out of prison. 

In addition to the others being out of prison already the government must not deem Michael that much of a threat, considering they could not even get their response in a timely manner. If I was in charge of keeping a horribly dangerous man in prison, I would definitely submit all of my information before the deadline. Their negligence in meeting the deadline shows me that they were not too fearful
The same crime that Michael was convicted of would hold about 16 years and if it was including the death of somebody during the commission of crime the average is about 20 years. Michael is at 28 years served of a 46 year sentence. This is considered inhumane 

Disciplinary Action

Disciplinary action for phone calls – Michael admits to a call where he has asked his sister to get his niece on the phone, his niece is a child however, he did do that three-way call
Write ups pertaining to the CO – while in USP Coleman and USP Lee county there had been multiple accounts of horrible correction and abuse to many of the inmates (so many complaints but now there was an investigation after he left. Multiple staff members of the prisons got arrested.) Michael told his sister about an officer putting pork on his bed when he is a Muslim, and while being patted down, was groped by a CO inappropriately and sexually. His sister filed a complaint in the next day got the complaint, and that officer was notified. Michael got  disciplinary action and then another complaint filed by the family. There are records of these complaints and who handled it.   
He also was given an infraction after a fight broke out, this incident was already resolved when the people that were involved in the fight made statements as to who was fighting and who were bystanders. The fight was between other men however there were multiple people that happen to be close by when the fight broke out suddenly. Multiple people got pepper sprayed, even though they weren’t involved because it was unknown who was involved.  They decided to write everybody up that was in the area, which eventually was cleared up, that write up was removed. 
Their response discusses all of these different disciplinary actions which are portrayed in a dishonest way, leaving information out. And she briefly mentioned the fact that he has multiple certificates however, she specifically lists 55 disciplinary records for an entire 28 years. His certificates speak volumes. In 2024 he received the certificate for being a suicide companion in the suicide prevention program. The description attached below. This is not a job that is given to every inmate. It is a very carefully selected job. Suicide companion roleis a job only to be given to somebody who is in good standing and a model for other inmates. Anybody who has been found to have committed a 100-level prohibited act within the last three years; or be in ERP, GED, or Drug Ed Refuse status cannot hold this job. A 100 level act usually involve violence or drugs. This description of his job further goes to show you that he not fighting and being violent the way the US attorney portrayed in the response. in fact he was and is respectful and helpful and serves to others as a role model where he is. There are only 20 or so men with this job in the entire prison.  I think the requirements of this position speak for themselves that Michael is definitely able to follow rules in prison as the government stated concerned that if he can’t follow rules in prison, how will he follow them outside of prison…

Claiming his father has a caregiver

US attorney has copy of everything that was turned in with the original motion. This includes signed letter that stated Michaels father has a terminal illness and that he needed a caregiver around the clock. It also states that the patient did not have a caregiver at all. It was signed by physician/hospice medical director and the hospice supervisor gave her phone number as well for any follow up questions
The RN case manager wrote a letter detailing patients specific admission diagnosis, as well as signs and symptoms that he is declining.  Also spoke to his need for a caregiving and observation that Michael is attentive to his father and interested in his medical condition.
Michael has a sister Tracee, who is unable to leave her small child- and other personal matters - to go to be her father’s primary caregiver 
Patient also has a son outside of Michael that does not speak to him. They are estranged and family members do not seem to know where he is.
Patients sister Brenda has been unable to come see him as she is 60+ years old herself and trying to work plus she lives in Georgia. Brenda also has a chronically ill adult child she cares for. She has told Michael Sr it is not an option for him to move there. They also have an older brother, who is in a nursing home, he was being cared for by his sister, but she could not take care of him any longer. 

The us attorney had these letters from the physician and nurse before writing their response where they lied and stated Michael’s dad has other options. I find it absolutely ridiculous and disgusting that this is the way our “justice” system is run. This poor man needs help and they turn around and write that he does not. They have the information of the jobs that Michael does in his certificates and they are able to see that the job description for the mental health companion.  

Dishonesty is OK?

The Attorney General signs an affidavit at the end of their response, stating that everything that they have said to their knowledge is true. I would like to know how everything that was said to their knowledge is true when they are holding paperwork in their hands stating the complete opposite. How are inmates supposed to have a chance against bold faced lies? This is not justice.