EFTA00018948.pdf

195 KB
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Extraction Summary

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

Document Information

Type: Legal correspondence / discovery response letter
File Size: 195 KB
Summary

This document is a discovery response letter from the U.S. Attorney's Office (SDNY) to defense counsel for Tova Noel and Michael Thomas, dated March 14, 2020. It provides specific timestamps and video file identifications from MCC surveillance footage on the night of Jeffrey Epstein's death (August 9-10, 2019), including times Epstein left his cell for a phone call and times the defendants were at their desk using computers. It also identifies an MCC technician named Hughwon Daniel.

People (7)

Name Role Context
Geoffrey S. Berman United States Attorney
Sender of the letter representing the Southern District of New York.
Jason E. Foy Defense Attorney
Recipient, representing the defense (Foy & Seplowitz LLC).
Montell Figgins Defense Attorney
Recipient, representing the defense (Law Offices of Montell Figgins).
Tova Noel Defendant
Defendant in Case No. 19 Cr. 830; subject of discovery requests regarding computer usage and location.
Michael Thomas Defendant
Defendant in Case No. 19 Cr. 830; subject of discovery requests regarding computer usage and location.
Jeffrey Epstein Inmate (Deceased)
Mentioned regarding surveillance footage of him leaving his cell for a phone call on August 9, 2019.
Hughwon Daniel MCC Technician
Identified in response to Noel Request No. 11.

Organizations (5)

Name Type Context
U.S. Department of Justice
Header organization
United States Attorney Southern District of New York
Prosecuting office
Foy & Seplowitz LLC
Defense firm
Law Offices of Montell Figgins
Defense firm
MCC
Metropolitan Correctional Center (implied by context of 'MCC technician' and 'Special Housing Unit')

Timeline (4 events)

2019-07-23
Date for which video surveillance of Special Housing Unit was requested (related to Tartaglione case context).
Special Housing Unit
2019-08-09
Jeffrey Epstein captured leaving his cell to make a phone call.
MCC Special Housing Unit
2019-08-09
Jeffrey Epstein escorted back to his cell.
MCC Special Housing Unit
2019-08-09 to 2019-08-10
Defendants Noel and Thomas at the desk using computers (Forensic examination correlation).
MCC

Locations (5)

Location Context
Sender location
Recipient location
Recipient location
Location within the correctional facility where surveillance video was requested for July 23, 2019.
MCC
Metropolitan Correctional Center, where Epstein was housed.

Relationships (3)

Tova Noel Co-defendants Michael Thomas
Case caption: United States v. Tova Noel and Michael Thomas
Hughwon Daniel Employee MCC
Referred to as 'MCC technician'
Jason E. Foy Legal Counsel (implied) Tova Noel
Addressed as counsel in US v Noel and Thomas; specific responses to 'Noel Requests'

Key Quotes (3)

"The name of the MCC technician referenced in the Government’s previous letter is Hughwon Daniel."
Source
EFTA00018948.pdf
Quote #1
"Epstein was captured leaving his cell to make a phone call at approximately 18:53:54 – 18:54:46"
Source
EFTA00018948.pdf
Quote #2
"The Government expressly reserves the right to identify and/or offer at trial additional material as probative of any of the issues identified in these requests."
Source
EFTA00018948.pdf
Quote #3

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