DOJ-OGR-00021994.jpg

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Extraction Summary

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

Document Information

Type: Legal correspondence / court filing (motion to adjourn)
File Size: 917 KB
Summary

A legal filing from the attorneys representing Tova Noel (one of the guards on duty when Epstein died) to Judge Analisa Torres requesting a delay in the trial date from April to October 2020. The defense cites the massive volume of discovery (877GB) and technical issues accessing it (incorrect password provided by the government) as reasons for the delay. The document specifically notes that the discovery includes video surveillance from three cameras covering the period of July 5, 2019, to August 12, 2019, but alleges the government still possesses unturned-over footage.

People (3)

Name Role Context
Analisa Torres United States District Court Judge
Recipient of the letter; presiding judge over the case.
Tova Noel Defendant
Subject of the case (US v. Tova Noel, et al); Epstein prison guard.
Defense Counsel (Foy & Seplowitz) Attorney
Author of the letter (implied by 'I' and letterhead); representing Tova Noel.

Organizations (3)

Name Type Context
Foy & Seplowitz LLC
Law firm representing the defendant.
United States District Court Southern District of New York
Court venue.
The Government
Prosecution team (DOJ/US Attorney's Office).

Timeline (5 events)

2019-07-05 to 2019-08-12
Period covered by video surveillance footage in discovery
Metropolitan Correctional Center (implied by context of case)
N/A
2019-11-25
Initial Status Conference
Southern District of New York
Court Defense Government
2019-12-31
Government forwarded discovery on hard drive
N/A
Government Defense Counsel
2020-01-04
Failed attempt to access discovery due to incorrect password
Defense Office
Defense Counsel
2020-04-20
Scheduled Trial Commencement (Original)
Southern District of New York
Tova Noel Government

Locations (4)

Relationships (2)

Tova Noel Attorney-Client Foy & Seplowitz LLC
Letter written on behalf of Ms. Noel requesting adjournment for effective assistance of counsel.
Tova Noel Adversarial (Legal) The Government
Case is US v. Tova Noel.

Key Quotes (4)

"The discovery contained in the initial production is 877GB of materials."
Source
DOJ-OGR-00021994.jpg
Quote #1
"In folder marked SDNY_00000001, there is video surveillance capturing 3 separate cameras from July 5, 2019 thru August 12, 2019."
Source
DOJ-OGR-00021994.jpg
Quote #2
"Note, that there is video surveillance in the Government's possession that has not been turned over"
Source
DOJ-OGR-00021994.jpg
Quote #3
"On January 4, 2020, I attempted to review the discovery and I could not access it because the Government provided the incorrect password to get access."
Source
DOJ-OGR-00021994.jpg
Quote #4

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