DOJ-OGR-00021994.jpg
917 KB
Extraction Summary
3
People
3
Organizations
4
Locations
5
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal correspondence / court filing (motion to adjourn)
File Size:
917 KB
Summary
A legal filing from the attorneys representing Tova Noel (one of the guards on duty when Epstein died) to Judge Analisa Torres requesting a delay in the trial date from April to October 2020. The defense cites the massive volume of discovery (877GB) and technical issues accessing it (incorrect password provided by the government) as reasons for the delay. The document specifically notes that the discovery includes video surveillance from three cameras covering the period of July 5, 2019, to August 12, 2019, but alleges the government still possesses unturned-over footage.
People (3)
| Name | Role | Context |
|---|---|---|
| Analisa Torres | United States District Court Judge |
Recipient of the letter; presiding judge over the case.
|
| Tova Noel | Defendant |
Subject of the case (US v. Tova Noel, et al); Epstein prison guard.
|
| Defense Counsel (Foy & Seplowitz) | Attorney |
Author of the letter (implied by 'I' and letterhead); representing Tova Noel.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Foy & Seplowitz LLC |
Law firm representing the defendant.
|
|
| United States District Court Southern District of New York |
Court venue.
|
|
| The Government |
Prosecution team (DOJ/US Attorney's Office).
|
Timeline (5 events)
2019-07-05 to 2019-08-12
Period covered by video surveillance footage in discovery
Metropolitan Correctional Center (implied by context of case)
N/A
2020-01-04
Failed attempt to access discovery due to incorrect password
Defense Office
Defense Counsel
Locations (4)
| Location | Context |
|---|---|
|
Jurisdiction.
|
|
|
Court address.
|
|
|
Law firm address.
|
|
|
Law firm address.
|
Relationships (2)
Letter written on behalf of Ms. Noel requesting adjournment for effective assistance of counsel.
Case is US v. Tova Noel.
Key Quotes (4)
"The discovery contained in the initial production is 877GB of materials."Source
DOJ-OGR-00021994.jpg
Quote #1
"In folder marked SDNY_00000001, there is video surveillance capturing 3 separate cameras from July 5, 2019 thru August 12, 2019."Source
DOJ-OGR-00021994.jpg
Quote #2
"Note, that there is video surveillance in the Government's possession that has not been turned over"Source
DOJ-OGR-00021994.jpg
Quote #3
"On January 4, 2020, I attempted to review the discovery and I could not access it because the Government provided the incorrect password to get access."Source
DOJ-OGR-00021994.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,358 characters)
Case 1:19-cr-00830-AT Document 20 Filed 01/27/20 Page 1 of 2
FOY & SEPLOWITZ LLC
attorneys at law
FOY & SEPLOWITZ LLC
attorneys at law
105 MAIN STREET
HACKENSACK, NJ 07601
TEL: 201-457-0071
FAX: 201-457-0072
HACKENSACK, NJ 07601
TEL: 201-457-0071
FAX: 201-457-0072
30 WALL STREET
8TH FLOOR
NEW YORK, NY 10005
TEL: 212-709-8230
8TH FLOOR
NEW YORK, NY 10005
TEL: 212-709-8230
WWW.FOYSEPLOWITZ.COM
January 27, 2020
FILED VIA ECF
Honorable Analisa Torres
United States District Court Judge
Southern District of New York
500 Pearl Street
New York, NY 10007
United States District Court Judge
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: US v. Tova Noel, et al
Docket # 19 cr. 830 (AT)
Request to Adjourn Trial Date
Docket # 19 cr. 830 (AT)
Request to Adjourn Trial Date
Dear Judge Torres:
On November 25, 2019, during the initial status conference the Court scheduled the above referenced criminal action for trial to commence on April 20, 2020. I am requesting that the trial date be postponed to sometime in October or a date thereafter that is convenient for the Court.
The adjournment is necessary to ensure that Ms. Noel receives adequate and effective assistance of counsel. The postponement of the trial will allow for the defense to review voluminous discovery and conduct a defense investigation of the case.
On November 22, 2019, I informed the Government that I would provide them with a hard drive during the November 25, 2019 initial status conference. On November 25, 2019, I provided the Government with a hard drive for discovery and the Government informed the Court that they would produce discovery in 30 days. The Government forwarded discovery on the hard drive to my office on December 31, 2019. The discovery was received by my office on January 2, 2020. On January 4, 2020, I attempted to review the discovery and I could not access it because the Government provided the incorrect password to get access. On January 6, 2020, I was provided with the correct password and gained my first access to the discovery.
The discovery contained in the initial production is 877GB of materials. The 877GB of materials contains up to 8118 Bates of global discovery and up to 20,853 Bates of individual discovery. In folder marked SDNY_00000001, there is video surveillance capturing 3 separate cameras from July 5, 2019 thru August 12, 2019. Each date allegedly contains the 24-hour period for each day, from each camera, and in 1-hour increments per individual file. Note, that there is video surveillance in the Government's possession that has not been turned over, however, the Government
DOJ-OGR-00021994
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