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Extraction Summary

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

Document Information

Type: Legal filing / court motion (defense memorandum)
File Size: 781 KB
Summary

This document is page 14 of a legal defense filing (Case 1:19-cr-00830-AT) dated April 9, 2020, regarding charges against prison guards Michael Thomas and Tova Noel. The defense argues that while Thomas is charged with falsifying logs, other supervisors who approved these logs were not charged, and points to severe staffing shortages in the SHU. The filing seeks disclosure of the Inspector General's report, arguing it is material to the defense to prove systemic failures beyond the defendants' actions.

People (3)

Name Role Context
Michael Thomas Defendant / BOP Employee
Charged with making false statements; defense argues he is being unfairly singled out while supervisors are not charged.
Tova Noel Defendant / BOP Employee
Mentioned alongside Thomas as the only two employees charged with making false statements.
Inspector General Government Official
Author of a report the defense is seeking to access.

Organizations (3)

Name Type Context
BOP
Employer of the defendants; supervisors mentioned as having approved the documents in question.
United States District Court
Implied by the case header (Case 1:19-cr-00830-AT).
DOJ
Indicated in the footer stamp (DOJ-OGR).

Timeline (2 events)

Night in question
Surveillance video allegedly shows Michael Thomas sleeping and surfing the internet instead of doing rounds.
SHU
Michael Thomas Surveillance Monitor (BOP Employee)
Unknown
The alleged crime took place in the SHU.
SHU
Unknown (implied Jeffrey Epstein)

Locations (2)

Location Context
SHU
Special Housing Unit where the 'alleged crime' took place and severe staffing shortages occurred.
Eastern District of New York, cited in case law (United States v. Ashley).

Relationships (2)

Michael Thomas Co-defendants/Colleagues Tova Noel
Cited together as the only two employees charged.
Michael Thomas Subordinate/Superior BOP Supervisors
Documents signed by Thomas 'have to be approved by supervisors'.

Key Quotes (5)

"severe staffing shortages in the SHU where the alleged crime took place and that these staffing shortages created a significant safety risk."
Source
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Quote #1
"why is Michael Thomas and Tova Noel the only two employees charged with making false statements."
Source
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Quote #2
"they have video showing Mr. Thomas sleeping and surfing the internet instead of doing the rounds as required."
Source
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Quote #3
"Plainly, the documents upon which the government procured an indictment based on making a false statement have to be reviewed, verified and signed by other BOP employees and/or supervisory personnel."
Source
DOJ-OGR-00022037.jpg
Quote #4
"The requested reports go to the heart of Mr. Thomas' defense."
Source
DOJ-OGR-00022037.jpg
Quote #5

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