022.pdf

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Extraction Summary

7
People
3
Organizations
5
Locations
4
Events
2
Relationships
4
Quotes

Document Information

Type: Legal correspondence / government response to motion
File Size: 63.6 KB
Summary

This document is a letter from the U.S. Attorney's Office (SDNY) to Judge Analisa Torres in the case of United States v. Noel and Thomas, dated January 28, 2020. The Government opposes the defendants' request for a six-month adjournment of the trial scheduled for April 20, 2020, arguing that the case focuses on a narrow 14-hour window (the night of Jeffrey Epstein's death) and that discovery has been provided promptly. The prosecutors state they would not object to a 'brief' adjournment but deem six months unnecessary.

People (7)

Name Role Context
Analisa Torres United States District Judge
Recipient of the letter, presiding over the case.
Tova Noel Defendant
Correctional officer charged in relation to Epstein's death; her counsel requested adjournment.
Michael Thomas Defendant
Correctional officer charged in relation to Epstein's death; his counsel requested adjournment.
Geoffrey S. Berman United States Attorney
Head of the SDNY office submitting the letter.
Rebekah Donaleski Assistant United States Attorney
Signatory of the letter.
Nicolas Roos Assistant United States Attorney
Signatory of the letter.
Jessica Lonergan Assistant United States Attorney
Signatory of the letter.

Organizations (3)

Name Type Context
U.S. Department of Justice
Header organization
United States Attorney Southern District of New York
Prosecuting office
MCC
Metropolitan Correctional Center (implied context for video surveillance mentions)

Timeline (4 events)

2019-07-23
Date of prior incident/events for which materials were produced (Epstein's first suicide attempt)
MCC New York
2019-08-09
Start of the 14-hour period relevant to charges (approx 4:00 p.m.)
MCC New York
2019-08-10
End of the 14-hour period relevant to charges (approx 6:30 a.m.) - Time of Epstein's death discovery
MCC New York
2020-04-20
Currently scheduled trial commencement date
SDNY Court

Locations (5)

Location Context
Jurisdiction
Address of US Attorney
Address of US Attorney
Address of the Court
City

Relationships (2)

Tova Noel Co-defendants Michael Thomas
Case caption 'United States v. Noel and Thomas'
Analisa Torres Judge and Prosecutor Rebekah Donaleski
Author and recipient of the legal filing

Key Quotes (4)

"The Government remains prepared to proceed to trial as scheduled."
Source
022.pdf
Quote #1
"the requested six-month adjournment is both unnecessary and unwarranted."
Source
022.pdf
Quote #2
"the charges in this case relate to a period of just over 14 hours—from approximately 4:00 p.m. on August 9, 2019 to approximately 6:30 a.m. the following day, August 10, 2019."
Source
022.pdf
Quote #3
"the Government did not obtain any search warrants as part of its investigation, nor did the defendants make post-arrest statements that the Government would seek to introduce into evidence."
Source
022.pdf
Quote #4

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