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Extraction Summary

7
People
4
Organizations
4
Locations
1
Events
3
Relationships
2
Quotes

Document Information

Type: Legal correspondence / discovery request
File Size: 503 KB
Summary

This document is a formal discovery request dated January 29, 2020, from Montell Figgins (attorney for Michael Thomas) to AUSA Rebekah Donaleski regarding the case 'United States v. Michael Thomas' (incorrectly listed as State of NY in the Re: line, but with federal docket 1:19-cr-00830). The letter requests all materials (reports, photos, videos) possessed by the United States Inspector General pursuant to Rule 16(a)(1)(C). It cites U.S. v. Bryan as legal precedent for the entitlement to these documents.

People (7)

Name Role Context
Montell Figgins Attorney
Defense attorney for Michael Thomas; author of the letter.
Rebekah Donaleski Assistant United States Attorney
Recipient of the letter; prosecutor in the SDNY.
Michael Thomas Defendant
Client of Montell Figgins; defendant in case 1:19-cr-00830 (Epstein prison guard case).
Noel Defendant
Co-defendant (Tova Noel); mentioned in CC line.
Jason Erroy Foy Attorney
Counsel for Defendant Noel; copied on the letter.
Kenneth E. Brown Associate
Listed on letterhead of Montell Figgins, LLC.
Linda Childs Associate
Listed on letterhead of Montell Figgins, LLC.

Organizations (4)

Name Type Context
The Law Offices of Montell Figgins, LLC
Law firm representing Michael Thomas.
Southern District of New York
Federal prosecutor's office handling the case.
United States Inspector General
Government body whose reports are being requested.
DOJ
Department of Justice (referenced in footer stamp).

Timeline (1 events)

2020-01-29
Formal Discovery Request made by defense counsel
New York/New Jersey

Locations (4)

Location Context
Primary office of Montell Figgins.
Address of the Southern District of New York (SDNY).
Branch office.
Branch office (Note: Zip code appears cut off or typos in source as 1005).

Relationships (3)

Montell Figgins Attorney/Client Michael Thomas
Signature block: 'Attorney for Defendant Michael Thomas'
Jason Erroy Foy Attorney/Client Noel
CC line: 'Counsel for Defendant Noel'
Rebekah Donaleski Prosecutor/Defendant Michael Thomas
Addressed to AUSA regarding 'v Michael Thomas'

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
DOJ-OGR-00022046.jpg
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
DOJ-OGR-00022046.jpg
Quote #2

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