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This document is a letter dated July 17, 2019, from attorney Reid Weingarten of Steptoe & Johnson LLP to Judge Richard M. Berman of the Southern District of New York. The letter is filed in the criminal case of United States v. Jeffrey Epstein and serves to submit documents concerning Epstein's registration status in New Mexico. This submission is made at the court's request and is intended to further support Epstein's application for bail.
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This document is a legal letter dated January 5, 2022, from attorney Jason E. Foy to Judge Analisa Torres, requesting a court order for the release of Tova Noel's firearm and other property. The letter explains that Noel's criminal charges were dismissed on January 3, 2022, and although she surrendered her firearm to the NYPD in 2019 as a condition of release, the NYPD property clerk refused to return it without a court order on January 4, 2022. The Government has expressed no objection to the proposed order.
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This legal document is a letter dated September 14, 2020, from attorney Montell Figgins to Judge Analisa Torres of the U.S. Southern District of New York. The letter formally requests the court's permission for the defendant, Michael Thomas, to take an emergency trip to the State of Georgia to care for his sick father. It also states that Thomas's pre-trial services officer, Kristen McKeown, does not oppose the travel request.
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This document is a letter dated September 8, 2020, from attorney Montell Figgins to Judge Analisa Torres of the U.S. Southern District of New York. Figgins requests an adjournment of the trial for his client, Michael Thomas, in the case State of NY v Michael Thomas, et al. (Docket No. 1:19-cr-00830). He asks to move the trial from January 4, 2021, to approximately May 3, 2021, citing COVID-19, his own health concerns, and the need for more time to complete his investigation.
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This legal document is a letter dated March 20, 2020, from attorney Montell Figgins to Judge Analisa Torres of the U.S. Southern District of New York. Figgins is requesting a 14-day extension to file a motion to dismiss for his client, Michael Thomas, in case number 1:19-cr-00830. The reason for the request is the significant disruption to his law practice caused by the ongoing pandemic.
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This legal document is a letter dated March 20, 2020, from attorney Montell Figgins to Judge Analisa Torres of the U.S. Southern District of New York. Figgins is requesting a 14-day extension to file a motion to dismiss on behalf of his client, defendant Michael Thomas, in case 1:19-cr-00830. The reason cited for the delay is the significant disruption to his law practice caused by the ongoing pandemic.
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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.
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This is a letter dated August 10, 2020, from Ghislaine Maxwell's attorney, Laura A. Menninger, to Judge Loretta A. Preska. The letter informs the court about newly discovered information that is critical to both Maxwell's civil case (Giuffre v. Maxwell) and her separate criminal case. Counsel explains they are currently barred from disclosing this information due to a protective order in the criminal case but intend to seek a modification of that order to share the details with the court.
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