DOJ-OGR-00021955.jpg

514 KB

Extraction Summary

2
People
3
Organizations
0
Locations
1
Events
1
Relationships
3
Quotes

Document Information

Type: Legal document (court order / protective order)
File Size: 514 KB
Summary

This document is page 2 of a Protective Order filed on December 16, 2019, in the criminal case against Tova Noel and Michael Thomas (the guards on duty when Jeffrey Epstein died). The order outlines restrictions on 'Protected Materials' provided during discovery, stipulating they can only be used for defense purposes and cannot be disclosed to third parties except as specifically allowed. The defendants consented to this order.

People (2)

Name Role Context
Tova Noel Defendant
Consented to the entry of the Order through counsel
Michael Thomas Defendant
Consented to the entry of the Order through counsel

Organizations (3)

Name Type Context
The Government
Demonstrated good cause for relief; designates 'Protected Materials'
Department of Justice
Indicated by footer 'DOJ-OGR'
Federal Court
Implied by Case Header and Federal Rules citation

Timeline (1 events)

2019-12-16
Document 13-1 filed in Case 1:19-cr-00830-AT
Federal Court (SDNY implied by case context)

Relationships (1)

Tova Noel Co-defendants Michael Thomas
Listed together as 'the defendants' in the document text

Key Quotes (3)

"WHEREAS, TOVA NOEL and MICHAEL THOMAS, the defendants, by and through their respective counsel of record, consent to the entry of this Order"
Source
DOJ-OGR-00021955.jpg
Quote #1
"Discovery materials designated as 'Protected Materials' by the Government may be used by the defendants... only for purposes of defending the charges"
Source
DOJ-OGR-00021955.jpg
Quote #2
"The Protected Materials... Shall not be disclosed in any form by the Defense to any third party"
Source
DOJ-OGR-00021955.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,280 characters)

Case 1:19-cr-00830-AT Document 13-1 Filed 12/16/19 Page 2 of 5
parties, could, among other things, impede ongoing investigations
and implicate the privacy and confidentiality interests of third
parties;
WHEREAS, the Government has demonstrated good cause for the
relief set forth herein;
WHEREAS, TOVA NOEL and MICHAEL THOMAS, the defendants, by and
through their respective counsel of record, consent to the entry
of this Order;
NOW, THEREFORE, IT IS HEREBY ORDERED, pursuant to Federal
Rule of Criminal Procedure 16(d):
1. Discovery materials designated as “Protected Materials”
by the Government may be used by the defendants, their respective
counsel of record, and their respective counsel of record’s agents
(collectively, the “Defense”) only for purposes of defending the
charges, in connection with any sentencing, and pursuing any
appeals, in relation to this criminal action.
2. The Protected Materials and the information contained or
disclosed therein:
a. Shall not be disclosed in any form by the Defense
to any third party except as set forth in paragraphs 2(b), 3, and
4 below;
b. May be disclosed to third parties only by the
defendants’ respective counsel of record and only to the following
persons (collectively, “Designated Persons”):
DOJ-OGR-00021955

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