DOJ-OGR-00021999.jpg

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Extraction Summary

4
People
4
Organizations
0
Locations
2
Events
1
Relationships
3
Quotes

Document Information

Type: Legal filing (government opposition to adjournment)
File Size: 984 KB
Summary

This document is page 2 of a government legal filing dated January 28, 2020, arguing against a defense request to adjourn the trial. The text references defendants 'Thomas' and 'Noel' (likely the guards on duty during Epstein's suicide), stating that the case revolves around a 'brief, fourteen-hour window' and is not complex enough to warrant a six-month delay. The government asserts it has already provided witness statements (3500 material) well in advance and notes that no search warrants were obtained nor did defendants make post-arrest statements.

People (4)

Name Role Context
Thomas Defendant
Likely Michael Thomas (Epstein guard); counsel intends to file a motion to dismiss the indictment.
Noel Defendant
Likely Tova Noel (Epstein guard); counsel reviewing discovery to determine motions.
Thomas's Counsel Legal Defense
Intends to file motion to dismiss.
Noel's Counsel Legal Defense
Reviewing discovery.

Organizations (4)

Name Type Context
United States Government
Opposing the adjournment request.
Second Circuit
Cited for legal precedent.
S.D.N.Y.
Southern District of New York; cited in case law.
DOJ
Department of Justice (referenced in footer stamp).

Timeline (2 events)

2019-12-31
Government produced witness statements ('3500 material') to the defense.
N/A
Government Defense Counsel
2020-01-28
Date of filing for this document.
S.D.N.Y.
Government

Relationships (1)

Thomas Co-defendants Noel
Document discusses legal strategies and motions for both defendants in the same case context.

Key Quotes (3)

"The Government’s case-in-chief turns on a brief, fourteen-hour window for which the evidence is limited and now available to the defendants."
Source
DOJ-OGR-00021999.jpg
Quote #1
"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
DOJ-OGR-00021999.jpg
Quote #2
"Noel’s counsel, however, identifies no reason to believe such a review is likely to result in the identification of any potential pre-trial motions"
Source
DOJ-OGR-00021999.jpg
Quote #3

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