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Case 1:19-cr-00830-AT Document 57 i P TSsDeageN pf 1
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT DATE FILED: 5/25/2021
SOUTHERN DISTRICT OF NEW YORK
hss xX
UNITED STATES OF
Case 1:19-cr-00830-AT Document56- Filed 05/25¥2atspPagextyof 5
DOCUMENT
ELECTRONICALLY FILED
DOC #:
UNITED STATES DISTRICT COURT DATE MILER: SOS0zl
SOUTHERN DISTRICT OF NEW YORK
United States of
Case 1:19-cr-00830-AT Document55 Filed 05/25/21 Page2of3
The foregoing obligations are continuing ones and apply to materials that become known to
the Government in the future. These obligations also
Case 1:19-cr-00830-AT Document53 Filed 05/21/21 Pagelof2
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New Yor
Case 1:19-cr-00830-AT Document 41 Filed 09/626 =
USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
UNITED STATES DISTRICT COURT DOC #:
SOUTHERN DISTRICT OF NEW YORK DATE FILED: 9/10/2020 _
UNITED STATES OF A
Case 1:19-cr-00830-AT Document 40
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
-\V-
Michael Thomas '
Defendant(s).
“Defendant Michael Thomas
participate in
Case 1:19-cr-00830-AT Document 36 Filed 06/09/20 Page /7of9
disclose.” Gov’t Opp. at 21-22. The Court cannot grant a motion to compel the Government to
produce a report that, at the time of this orde
Case 1:19-cr-00830-AT Document36 Filed 06/09/20 Page5of9
arises where the Government conducts a joint investigation with another agency.” United States
v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y.
Case 1:19-cr-00830-AT Document36 Filed 06/09/20 Page1of9
USDC SDNY
UNITED STATES DISTRICT COURT DOCUMENT
SOUTHERN DISTRICT OF NEW YORK ELECTRONICALLY FILED
UNITED STATES OF AMERICA, DOC #:
DATE FIL
Case 1:19-cr-00830-AT Document35 Filed 04/24/20 Page 32 of 34
those officers “in 2005 or 2006” did falsify count slips, Thomas has still not put forth any evidence
that those officers were “outside o
Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 31 of 34
intent”); Fares, 978 F.2d at 59 (same). “[T]he showing necessary to obtain discovery should itself
be a significant barrier to the litig
Case 1:19-cr-00830-AT Document35 Filed 04/24/20 Page 27 of 34
such, there are no drafts of the Report to disclose, and Thomas’s motion can be denied on that
reason alone. Moreover, Thomas’s request f
Case 1:19-cr-00830-AT Document35 Filed 04/24/20 Page 24 of 34
ee Discussion
As described above, the Government has produced Brady, Giglio, and Rule 16 material in
the possession of the prosecutors a
Case 1:19-cr-00830-AT Document35 Filed 04/24/20 Page 18 of 34
and willfully made a false statement. Nor are those excuses relevant to whether Thomas had a
criminal agreement with his co-defendant. In
Case 1:19-cr-00830-AT Document35 Filed 04/24/20 Page 14 of 34
that the Indictment relates to a 14-hour time period); count slips, thirty minute round forms, and
staffing rosters for the three-week pe
Case 1:19-cr-00830-AT Document35 Filed 04/24/20 Page 10 of 34
written statements, photos, videos, and incident reports created, manufactured or possessed by the
United States Inspector General.” Noel
Case 1:19-cr-00830-AT Document35 Filed 04/24/20 Page 7 of 34
policies which relate to the “much larger context” at the BOP (Mot. 6, 7, 9, 10).
AS an initial matter, the Government has satisfied its
\ Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page 27 of 38
United States Department of Justice
Office of the Inspector General
Consent to Search Computer/Electronic Equipment
I, vi ( ( " a [a
Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page 19 of 38
“favorable” under Brady and must be disclosed by the government. Jd. at 676-77; see also Giglio
v. United States, 405 U.S. 150, 154-55 (
Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page 18 of 38
Undoubtedly, the government is going to assert that the requested documents in this
motion are not relevant or material and do not bear
Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page 15 of 38
government agencies because it is highly relevant to Mr. Thomas’ defense in this case.
Furthermore, the government had Mr. Thomas sign a
Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page 14 of 38
informed that there were severe staffing shortages in the SHU where the alleged crime took place
and that these staffing shortages creat
Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page 11 of 38
5. As to both defendants, any and all reports, memorandums, written
statements, photos, videos, and incident reports created, manufactur
Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page5of38
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA, 19 Cr. 830-2(AT)
-against-
Oral Argument Requested
TO
Case 1:19-cr-00830-AT Document 22 Filed 01/28/20 Page2of3
January 28, 2020
Page 2
Government also produced 3500 material for every individual interviewed during the investigation
in December, nearly
_. Case 1:19-cr-00830-AT Document 22 Filed 01/28/20 Page 1of3
oe U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
Case 1:19-cr-00830-AT Document 21 Filed 01/27/20 Pagelof2
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17 Academy Street, Suite 305
Newark, New Jersey 07102
Phone: (973) 242-4700
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Case 1:19-cr-00830-AT Document 14
JBJKNOEN
Filed 12/16/19 Page 4of12 4
Count O
Case 1:19-cr-00830-AT Document9 Filed 11/19/19 Page8sof8
DOCKET No, 19 Cr 830 (AT) DEFENDANT Tova Noel
AUSA Nicolas Roos DEF.S COUNSEL James E. Foy
Wireramep Clreperat DEFENDERS Lica LJ pRESENTMENT
Case 1:19-cr-00830-AT Document8 Filed 11/19/19 Page 10 of 10
' DOCKET No. 19 Cr 830 (AT) DEFENDANT Michael Thomas
AUSA Nicolas Roos DEF,.’S COUNSEL Montel Figgins
Wireranep () rEpERAL DEFENDERS Lici
Case 1:19-cr-00830-AT Document? Filed 11/19/19 Pagelof1
DOCKET No. 19 Cr 830 (AT) DEFENDANT Michael Thomas
AUSA Nicolas Roos DEF.’S COUNSEL Montel Figgins
Mirerainsp (J repera parenpers CL] cia Cb pr
Case 1:19-cr-00830-AT Document1 Filed 11/19/19 Page 17 of 20
administration of any matter within the jurisdiction of any
department or agency of the United States, and did attempt to do
the same, to
Case 1:19-cr-00830-AT Document1 Filed 11/19/19 Page 18 of 20
performed the 3 a.m. institutional count of the SHU, when they had
not in fact done so.
(Title 18, United States Code, Sections 1001(a) (
Case 1:19-cr-00830-AT Document1 Filed 11/19/19 | Page 20 of 20
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
om OV, —_
TOVA NOEL and
MICHAEL THOMAS,
Defendan
Case 1:19-cr-00830-AT Document1 Filed 11/19/19 Page 16 of 20
34. On or about August 9, 2019, in the Southern District
of New York, TOVA NOEL, the defendant, willfully and knowingly did
make and use
Case 1:19-cr-00830-AT Document1 Filed 11/19/19 Page 15 of 20
COUNT TWO
(False Records — 4 p.m. Count)
The Grand Jury further charges:
31. The Grand Jury incorporates the allegations
contained in pa
Case 1:19-cr-00830-AT Document1 Filed 11/19/19 Page 13 of 20
27. Epstein was transferred to a local hospital where
he was declared dead shortly thereafter. The Office of the Chief
Medical Examiner of
Case 1:19-cr-00830-AT Document1 Filed 11/19/19 Page 1 of 20
“UNITED STATES DISTERICT COURT
SOUTHERN DISTRICT OF NEW YORK
Se a=
INDICTMENT
UNITED STATES OF AMERICA
19
- Vv. -
TOVA NOEL and
MICHAEL
Case 22-1426, Document 121-2, 12/02/2024, 3637741, Page26 of 26
1. The District Court did not err in holding that Epstein’s NPA
with USAO-SDFL did not bar Maxwell’s prosecution by USAO-
SDNY.
2. The
Case 22-1426, Document 121-2, 12/02/2024, 3637741, Page23 of 26
“materially different” from the allegations in the Indictment. The
evidence indicated that Maxwell transported Jane to New York for
sex
Case 22-1426, Document 121-2, 12/02/2024, 3637741, Page22 of 26
a violation of New York law.”* It is therefore not “uncertain whether
[Maxwell] was convicted of conduct that was the subject of the gr
Case 22-1426, Document 121-2, 12/02/2024, 3637741, Page20 of 26
Maxwell subsequently filed a letter seeking reconsideration of the
District Court’s response, claiming that this response resulted in a
Case 22-1426, Document 121-2, 12/02/2024, 3637741, Page21 of 26
likelihood that the defendant may have been convicted of an offense
other than that charged in the indictment.”*° A constructive
amend
Case 22-1426, Document 121-2, 12/02/2024, 3637741, Page19 of 26
enough; the District Court did not abuse its discretion in denying
Maxwell’s motion for a new trial.*4
4. The District Court’s Respon
Case 22-1426, Document 121-2, 12/02/2024, 3637741, Page14 of 26
Indictment. The District Court therefore correctly denied Maxwell’s
motion without an evidentiary hearing.
2. The Indictment Is Timely
Case 22-1426, Document 121-2, 12/02/2024, 3637741, Page10 of 26
contemplates a broader restriction.”" And while Maxwell contends
that we cannot apply Annabi to an agreement negotiated and executed
ou
Case 22-1426, Document 121-2, 12/02/2024, 3637741, Page9 of 26
District Court imposed a $750,000 fine and a $300 mandatory special
assessment. This appeal followed.
II. DISCUSSION
1. The NPA Betwee
Case 22-1426, Document 121-2, 12/02/2024, 3637741, Page6 of 26
Statutes § 796.07,7 and to one count of solicitation of minors to engage
in prostitution, in violation of Florida Statutes § 796.03.° He
Case 22-1426, Document 121-2, 12/02/2024, 3637741, Paged5 of 26
Indictment. Lastly, we hold that Maxwell’s sentence is procedurally
reasonable.
Accordingly, we AFFIRM the District Court’s June 29,