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.
| 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)
|
| 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
|
| Location | Context |
|---|---|
|
Primary office of Montell Figgins
|
|
|
Branch office location
|
|
|
Branch office location
|
"I intend on filing a motion for dismissal based on selective prosecution."Source
"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
"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
Complete text extracted from the document (1,782 characters)
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