EFTA00017811.pdf
60.4 KB
Extraction Summary
6
People
3
Organizations
3
Locations
0
Events
3
Relationships
2
Quotes
Document Information
Type:
Legal correspondence / discovery request
File Size:
60.4 KB
Summary
A formal discovery request letter from Montell Figgins, attorney for Michael Thomas (one of the guards on duty when Jeffrey Epstein died), addressed to an Assistant US Attorney in the SDNY. The letter requests all materials (reports, photos, videos) created or possessed by the United States Inspector General regarding the incident. The letter cites Rule 16(a)(1)(C) and U.S. v. Bryan as legal basis for the request.
People (6)
| Name | Role | Context |
|---|---|---|
| Montell Figgins | Attorney |
Sender; Counsel for Defendant Michael Thomas
|
| Michael Thomas | Defendant |
Defendant in case 1:19-cr-00830 (Epstein prison guard)
|
| Kenneth E. Brown | Associate |
Listed on letterhead
|
| Linda Childs | Associate |
Listed on letterhead
|
| Jason Erroy Foy | Attorney |
Counsel for Defendant Noel; CC recipient
|
| Noel | Defendant |
Co-defendant mentioned in CC (refers to Tova Noel)
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Law Offices of Montell Figgins, LLC |
Sender's law firm
|
|
| Southern District of New York (SDNY) |
Recipient organization (US Attorney's Office)
|
|
| United States Inspector General |
Entity whose reports are being requested
|
Locations (3)
| Location | Context |
|---|---|
|
Address of Southern District of New York
|
|
|
Location of sender's office
|
|
|
Address of US Attorney's Office
|
Relationships (3)
Signed 'Attorney for Defendant Michael Thomas'
CC line: 'Counsel for Defendant Noel'
Case title 'v Michael Thomas, et al.' and CC to Noel's counsel
Key Quotes (2)
"I am making a formal request pursuant to Rule 16(a)(1)(C) for any and all reports, memorandums, written statements, photos, videos, and incident reports created, manufactured or possessed by the United States Inspector General."Source
EFTA00017811.pdf
Quote #1
"Please see U.S. v. Bryan, 868 F.2d 1032 (1989) if you maintain that Mr. Thomas is not entitled to the requested documents."Source
EFTA00017811.pdf
Quote #2
Full Extracted Text
Complete text extracted from the document (970 characters)
The Law Offices of
MONTELL FIGGINS, LLC
www.figginslaw.com
BRANCH OFFICES:
Reply to Newark Office [X]
ASSOCIATES
Kenneth E. Brown, Esq.
Linda Childs, Esq.
MONTELL FIGGINS, LLC
www.figginslaw.com
BRANCH OFFICES:
Reply to Newark Office [X]
ASSOCIATES
Kenneth E. Brown, Esq.
Linda Childs, Esq.
January 29, 2020
SENT VIA EMAIL
[Redacted]
Assistant United States Attorneys
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
[Redacted]
Assistant United States Attorneys
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Re: State of NY v Michael Thomas, et al.
Docket No.: 1:19-cr-00830
Discovery Request
Docket No.: 1:19-cr-00830
Discovery Request
Dear Ms. [Redacted]
As previously discussed, I am making a formal request pursuant to Rule 16(a)(1)(C) for any and all reports, memorandums, written statements, photos, videos, and incident reports created, manufactured or possessed by the United States Inspector General.
Please see U.S. v. Bryan, 868 F.2d 1032 (1989) if you maintain that Mr. Thomas is not entitled to the requested documents.
Respectfully yours,
/s/ Montell Figgins
Montell Figgins, Esq.
Attorney for Defendant Michael Thomas
/s/ Montell Figgins
Montell Figgins, Esq.
Attorney for Defendant Michael Thomas
cc: Jason Erroy Foy, Esq, Counsel for Defendant Noel via ECF
EFTA00017811
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