EFTA00031435.pdf

120 KB

Extraction Summary

9
People
8
Organizations
5
Locations
2
Events
2
Relationships
3
Quotes

Document Information

Type: Legal correspondence / discovery letter
File Size: 120 KB
Summary

This document is a discovery letter dated April 14, 2021, from the U.S. Attorney's Office (SDNY) to the defense counsel for Michael Thomas, one of the guards charged in connection with Jeffrey Epstein's death. The letter lists produced discovery materials including FBI reports and MCC documents, and provides statistical data from the Bureau of Prisons regarding disciplinary actions for log falsification and a list of inmate deaths at MCC and MDC over the last ten years, specifically listing Jeffrey Epstein's cause of death as 'Hanging' on August 10, 2019.

People (9)

Name Role Context
Michael Thomas Defendant
Defendant in case No. 19 Cr. 830 (Epstein guard)
Montell Figgins Defense Attorney
Counsel for Michael Thomas, recipient of the letter
Audrey Strauss U.S. Attorney
Sender of the letter, Southern District of New York
Jeffrey Epstein Inmate/Deceased
Listed in BOP death records table. DOD: 8/10/2019, Cause: Hanging
Tony McClam Inmate/Deceased
Listed in BOP death records table. DOD: 9/24/2020, Cause: Cardiac
Kenneth Houck Inmate/Deceased
Listed in BOP death records table. DOD: 5/19/2020, Cause: Hanging
Eric Manson Inmate/Deceased
Listed in BOP death records table. DOD: 10/23/2019, Cause: Drug Overdose
Oscar Reynoso Inmate/Deceased
Listed in BOP death records table. DOD: 10/23/2015, Cause: Hanging
Fang Xin He Inmate/Deceased
Listed in BOP death records table. DOD: 7/19/2012, Cause: Hanging

Organizations (8)

Name Type Context
U.S. Department of Justice
Header
United States Attorney Southern District of New York
Prosecuting office
Law Offices of Montell Figgins
Defense counsel firm
Bureau of Prisons (BOP)
Source of information regarding inmate deaths and disciplinary actions
Metropolitan Correctional Center (MCC)
Institution where Epstein and others died
Metropolitan Detention Center (MDC)
Institution where other listed inmates died
FBI
Mentioned in discovery materials (Import forms, Laboratory examination requests, process reports)
US Marshals Service
Mentioned in discovery materials (Intake and Personal History)

Timeline (2 events)

2019-08-10
Death of Jeffrey Epstein
MCC / Community Hospital
2021-04-14
Production of discovery materials
New York, NY

Locations (5)

Location Context
SDNY Address
Recipient Address
MCC
Metropolitan Correctional Center, New York
MDC
Metropolitan Detention Center
Location of death for Epstein, Manson, and Reynoso

Relationships (2)

Michael Thomas Attorney-Client Montell Figgins
Letter addressed to Figgins regarding 'United States v. Michael Thomas'
Jeffrey Epstein Inmate MCC
Listed in inmate death table with Institution: MCC

Key Quotes (3)

"The BOP has records of the following inmate deaths over the last ten years at the MCC and MDC"
Source
EFTA00031435.pdf
Quote #1
"Since approximately January 1, 2019, in BOP matters that resulted in sustained administrative charges of falsification with regard to log entries, the following disciplinary actions were taken: 2 letters of reprimand; 50 suspensions; 1 demotion; 3 terminations; and 6 resignations/retirements prior to discipline."
Source
EFTA00031435.pdf
Quote #2
"Jeffrey Epstein | 76318-054 | 8/10/2019 | MCC | Community Hospital | Hanging"
Source
EFTA00031435.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (3,249 characters)

U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
April 14, 2021
BY USAfx
Montell Figgins, Esq.
Law Offices of Montell Figgins
17 Academy Street, Suite 305
Newark, NJ 07102
Re: United States v. Michael Thomas, No. 19 Cr. 830
Dear Counsel:
This letter provides additional discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure. This letter and the materials identified herein are subject to the protective order entered in this case on December 16, 2019, and have been designated as "Protected Materials" as defined in the order where noted below. Accordingly, the materials and information identified herein shall not be disclosed to any third party or referenced publicly except as set forth in the protective order.
[Table]
Description | Bates Numbers | Classification Pursuant to Protective Order
Arrest documentation and signed warrants | SDNY_00017773 – SDNY_00017775 | Confidential
Documents from the MCC including quarters, maps, and rosters | SDNY_00017776 – SDNY_00017782 | Confidential
FBI import forms | SDNY_00017783 – SDNY_00017822 | Confidential
FBI Laboratory examination requests | SDNY_00017823 – SDNY_00017825 | Confidential
FBI process reports | SDNY_00017826 – SDNY_00017991 | Confidential
Witness statements | SDNY_00017992 – SDNY_00018024 | Confidential
Anonymized index | SDNY_00018025 | Attorney’s Eyes Only
Additionally, the Government is producing the following materials only to your client:
06.20.2018
EFTA00031435
Page 2
[Table Continued]
Description | Bates Numbers | Classification Pursuant to Protective Order
US Marshals Service Intake and Personal History | SDNY_MT_00000212 – SDNY_MT_00000223 | [Blank]
Finally, while we do not agree these materials are required to be produced pursuant to Rule 16, based on your prior request for information, the Government is providing the following information from the Bureau of Prisons ("BOP"):
• Since approximately January 1, 2019, in BOP matters that resulted in sustained administrative charges of falsification with regard to log entries, the following disciplinary actions were taken: 2 letters of reprimand; 50 suspensions; 1 demotion; 3 terminations; and 6 resignations/retirements prior to discipline.
• The BOP has records of the following inmate deaths over the last ten years at the MCC and MDC:
Inmate Name | Register Num | DOD | Institution | Death Location | Cause of Death
Tony McClam | 79490-054 | 9/24/2020 | MCC | Housing Unit | Cardiac
Kenneth Houck | 06743-015 | 5/19/2020 | MDC | Special Housing Unit | Hanging
Eric Manson | 01558-112 | 10/23/2019 | MCC | Community Hospital | Drug Overdose
Jeffrey Epstein | 76318-054 | 8/10/2019 | MCC | Community Hospital | Hanging
Oscar Reynoso | 60240-019 | 10/23/2015 | MDC | Community Hospital | Hanging
Fang Xin He | 79018-053 | 7/19/2012 | MDC | Mental Health Unit | Hanging
The foregoing information is subject to the protective order. Please contact us with any questions.
Very truly yours,
AUDREY STRAUSS
United States Attorney for the
Southern District of New York
By: /s/ [REDACTED SIGNATURE BLOCK]
Assistant United States Attorneys
06.20.2018
EFTA00031436

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