DOJ-OGR-00021997.jpg

625 KB

Extraction Summary

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

Document Information

Type: Legal correspondence / court filing (letter)
File Size: 625 KB
Summary

This document is a legal letter filed on January 27, 2020, by Montell Figgins, the attorney for Michael Thomas (a prison guard charged in connection with Jeffrey Epstein's death). Figgins states his intent to file a motion for dismissal based on selective prosecution and argues that the defense needs more time and access to Inspector General reports to prepare for trial, noting the government took over 90 days to investigate the incident. The letter is copied to prosecutors and counsel for the co-defendant, Noel.

People (9)

Name Role Context
Montell Figgins Attorney
Attorney for Defendant Michael Thomas; Author of the letter
Michael Thomas Defendant
Client of Montell Figgins; facing prosecution related to prison incident
Kenneth E. Brown Associate Attorney
Listed on letterhead for Montell Figgins, LLC
Linda Childs Associate Attorney
Listed on letterhead for Montell Figgins, LLC
Nicolas Roos Counsel for Plaintiff
CC recipient
Rebekah Donaleski Counsel for Plaintiff
CC recipient
Jessica Lonergan Counsel for Plaintiff
CC recipient
Jason Erroy Foy Counsel for Defendant Noel
CC recipient; attorney for co-defendant
Noel Defendant
Co-defendant mentioned in CC block (referring to Tova Noel)

Organizations (5)

Name Type Context
The Law Offices of Montell Figgins, LLC
Law firm representing Michael Thomas
Federal Bureau of Prisons
Government agency whose policies are being requested in discovery
Justice Department
Investigative body mentioned
FBI
Investigative body mentioned
Inspector General's Office
Investigative body mentioned; reports requested from this office

Timeline (2 events)

2020-01-27
Filing of Document 21 in Case 1:19-cr-00830-AT
Court (SDNY implicit based on case number)
April 2020
Projected trial timeline mentioned
Court

Locations (3)

Location Context
Primary office of Montell Figgins
Branch office location
Branch office location

Relationships (3)

Montell Figgins Attorney/Client Michael Thomas
Signed as 'Attorney for Defendant Michael Thomas'
Jason Erroy Foy Attorney/Client Noel
Listed as 'Counsel for Defendant Noel'
Michael Thomas Co-Defendants Noel
Implied by the structure of the case and counsel listings

Key Quotes (3)

"I intend on filing a motion for dismissal based on selective prosecution."
Source
DOJ-OGR-00021997.jpg
Quote #1
"My client’s position is also that we are entitled to any and all reports, memorandums, witness statements and investigative reports written, produced or possessed by the inspector general regarding this incident"
Source
DOJ-OGR-00021997.jpg
Quote #2
"It should be noted, that it took the justice department, the FBI, the inspector general’s office and an assortment of other federal agencies more than 90 days to investigate this matter."
Source
DOJ-OGR-00021997.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,782 characters)

Case 1:19-cr-00830-AT Document 21 Filed 01/27/20 Page 2 of 2
The Law Offices of
MONTELL FIGGINS, LLC
17 Academy Street, Suite 305
Newark, New Jersey 07102
Phone: (973) 242-4700
Fax: (973) 242-4701
www.figginslaw.com
BRANCH OFFICES:
140 East Ridgewood Avenue
Paramus, NJ 07640
30 Wall Street 8th Floor
New York, NY 1005
Reply to Newark Office [X]
ASSOCIATES
Kenneth E. Brown, Esq.
Linda Childs, Esq.
As previously noted, I intend on filing a motion for dismissal based on selective prosecution. If successful, this motion will entitle my client to additional discovery beyond what has previously been provided which also pushes the trial timeline beyond April of 2020.
My client’s position is also that we are entitled to any and all reports, memorandums, witness statements and investigative reports written, produced or possessed by the inspector general regarding this incident and the Federal Bureau of Prison’s policy regarding written statements and employee conduct.
It should be noted, that it took the justice department, the FBI, the inspector general’s office and an assortment of other federal agencies more than 90 days to investigate this matter. Accordingly, it is more than reasonable that it would take the defendant and his counsel, who have less than one percent of the man power and resources of the government, a significantly longer time to accomplish an adequate investigation and review of all the necessary information provided in this case.
Respectfully yours,
/s/ Montell Figgins
Montell Figgins, Esq.
Attorney for Defendant Michael Thomas
cc: Nicolas Roos, Esq., Counsel for Plaintiff
Rebekah Donaleski, Esq., Counsel for Plaintiff
Jessica Lonergan, Esq., Counsel for Plaintiff
Jason Erroy Foy, Esq, Counsel for Defendant Noel
DOJ-OGR-00021997

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