THOMAS
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
organization
GOVERNMENT
|
Legal representative |
10
Very Strong
|
9 | |
|
person
Noel
|
Business associate |
7
|
3 | |
|
organization
The government
|
Legal representative |
7
|
3 | |
|
person
Noel
|
Co defendants |
6
|
2 | |
|
organization
BOP
|
Professional |
5
|
1 | |
|
location
United States
|
Legal representative |
5
|
1 | |
|
person
The prosecution
|
Legal representative |
5
|
1 | |
|
person
Noel
|
Co defendants co workers |
5
|
1 | |
|
person
Gonzales
|
Legal representative |
5
|
1 | |
|
organization
Bureau of Prisons
|
Legal representative |
5
|
1 | |
|
organization
BOP
|
Employee |
5
|
1 | |
|
person
JE
|
Professional |
5
|
1 | |
|
person
Government/BOP
|
Legal representative |
5
|
1 | |
|
person
MONTELL FIGGINS
|
Legal representative |
3
|
3 | |
|
person
Epstein
|
Legal representative |
1
|
1 | |
|
organization
U.S. Attorney's Office
|
Legal representative |
1
|
1 | |
|
person
OIG Attorneys
|
Investigative |
1
|
1 | |
|
person
[Redacted Staff Member]
|
Business associate |
1
|
1 | |
|
person
Noel
|
Co defendants subjects |
1
|
1 | |
|
person
Jeffrey Epstein
|
Guard inmate implied |
1
|
1 | |
|
person
[REDACTED] (DTS)
|
Professional supervisory |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 1996-01-01 | Legal case | Legal case cited: Gonzales v. Thomas, 99 F.3d 978 (10th Cir. 1996). | N/A | View |
| 1994-01-01 | Court case | Thomas v. I.N.S., 35 F.3d 1332 (9th Cir. 1994) | 9th Circuit | View |
DOJ-OGR-00022091.jpg
This page is from a legal filing (Document 35, filed 04/24/20) in the case against Thomas (likely Michael Thomas, a guard involved in the Epstein case). The prosecution argues that Thomas is not entitled to draft OIG reports under Rule 16 or Brady obligations. Furthermore, the text argues Thomas has failed to meet the burden of proof required to demand discovery to support a 'selective prosecution' claim, specifically failing to prove discriminatory intent or effect regarding his charges relative to rampant conduct within the Bureau of Prisons.
DOJ-OGR-00022090.jpg
This legal document is a portion of a court filing arguing against a motion made by an individual named Thomas. The prosecution contends that a draft report and related work product from the Department of Justice's Office of the Inspector General (DOJ-OIG) concerning Jeffrey Epstein's incarceration are protected by the deliberative process privilege and should not be disclosed. The filing asserts that while underlying materials have been provided, Thomas's claim for additional information is speculative and unsupported.
DOJ-OGR-00022089.jpg
This page is from a legal filing (Case 1:19-cr-00830-AT) dated April 24, 2020, arguing against a motion by defendant Thomas (likely Michael Thomas, a guard involved in the Epstein case) to disclose draft versions of an Inspector General's Report regarding the Bureau of Prisons (BOP). The text argues that such drafts do not yet exist and, even if they did, would be protected by the 'deliberative process privilege.' The document cites numerous legal precedents to support the claim that pre-decisional government documents are shielded from discovery.
DOJ-OGR-00022088.jpg
This legal document is a portion of a government filing arguing against a defendant's (Thomas) motion for discovery. The government contends that searching for certain records from the BOP, CIA, and Vice President's office would be an undue burden and that a draft Inspector General report is not subject to disclosure because it is not material to the defense and is protected by deliberative process privilege. The government states the report is not yet complete and the prosecution team has no involvement in its creation.
DOJ-OGR-00022087.jpg
This page is from a legal filing (Case 1:19-cr-00830-AT) filed on April 24, 2020, involving the prosecution of prison guards (specifically defendant Thomas) related to the events of August 9-10, 2019 (Jeffrey Epstein's suicide). The Government argues against Thomas's request for BOP records regarding staffing shortages and prior instances of falsified records, asserting that the BOP was not part of the prosecution team and therefore the Government is not obligated to search BOP files under discovery rules. The text cites legal precedents (U.S. v. Bryan, U.S. v. Volpe) to support the limitation of 'government' to only those agencies participating in the specific investigation.
DOJ-OGR-00022081.jpg
This document is page 19 of a legal filing (Document 35) from case 1:19-cr-00830-AT, filed on April 24, 2020. It contains the Government's legal argument opposing discovery requests made by the defendant, Thomas (likely Michael Thomas, a guard involved in the Epstein jail case). The Government argues that Thomas's requests are irrelevant to the charges and are instead an attempt to 'garner sympathy' and argue 'jury nullification,' citing various legal precedents to support the exclusion of such evidence.
DOJ-OGR-00022077.jpg
This legal document is a section of a government filing arguing against a defendant's (Thomas) request for certain records. The government contends that the records—related to BOP staffing, policies, and other employees—are not 'material' to preparing a legal defense under Rule 16. Instead, the government asserts Thomas seeks these records for the impermissible purpose of encouraging jury nullification by arguing that poor conditions at the BOP 'led' to his alleged criminal conduct.
DOJ-OGR-00022072.jpg
This document is page 5 of a court filing (Document 35) from April 24, 2020, in the case against prison guards Noel and Thomas (Case 1:19-cr-00830-AT). It details legal maneuvering regarding discovery, specifically focusing on requests for MCC video surveillance footage and reports from the Inspector General. The text notes that Thomas considered filing a motion to dismiss based on 'selective prosecution' but failed to do so by the deadline.
DOJ-OGR-00022070.jpg
This document is page 8 of a court filing (Document 35) from April 2020 regarding the criminal case against correctional officers Noel and Thomas. It details the charges related to their failure to perform prisoner counts at the MCC SHU between August 9 and 10, 2019 (the night of Jeffrey Epstein's death) and their falsification of records. It also outlines the timeline of pretrial discovery, noting that the Government provided surveillance video, computer analysis, and interview reports to the defense.
DOJ-OGR-00022064.jpg
This document is the table of contents for a legal filing (Document 35) in case 1:19-cr-00830-AT, filed on April 24, 2020. It outlines the government's legal arguments against providing additional discovery materials to a defendant named Thomas. The arguments assert that the government has met its obligations, the requested materials are not relevant, and they are not required to collect materials from agencies outside the prosecution team.
DOJ-OGR-00021999.jpg
This document is page 2 of a government legal filing dated January 28, 2020, arguing against a defense request to adjourn the trial. The text references defendants 'Thomas' and 'Noel' (likely the guards on duty during Epstein's suicide), stating that the case revolves around a 'brief, fourteen-hour window' and is not complex enough to warrant a six-month delay. The government asserts it has already provided witness statements (3500 material) well in advance and notes that no search warrants were obtained nor did defendants make post-arrest statements.
DOJ-OGR-00021953.jpg
This is a legal filing from the U.S. Attorney's Office for the Southern District of New York, dated December 16, 2019, addressed to Judge Analisa Torres. The letter, concerning the case *United States v. Noel and Thomas* (the guards charged in relation to Jeffrey Epstein's death), submits a proposed protective order for the court's endorsement with the consent of the defense counsel. The document is signed by Assistant US Attorneys Donaleski, Roos, and Lonergan on behalf of US Attorney Geoffrey Berman.
DOJ-OGR-00021910.jpg
This legal document, filed November 19, 2019, details the work schedule of a correctional officer named THOMAS, who worked overtime shifts in the Special Housing Unit (SHU) of the Metropolitan Correctional Center (MCC) on August 9 and 10, 2019. The document provides context for these shifts by noting they occurred during the period of Jeffrey Epstein's incarceration at the MCC, which ended with his suicide on August 10, 2019. It also describes the security and layout of the SHU.
DOJ-OGR-00021840.jpg
This legal document, a page from a court filing, argues that a plea agreement made by a United States Attorney's Office (USAO) in one district is generally binding on other USAOs and the federal government as a whole. It cites several court cases, such as Gebbie and Van Thournout, to support this majority view, while also acknowledging contrary or more limited rulings from circuits like the Seventh and Sixth in a footnote.
DOJ-OGR-00009045.jpg
This document is page 44 of a legal filing (Document 613) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on February 24, 2022. The text presents legal arguments regarding 'inferable bias' in jury selection, citing precedents such as *United States v. Torres*, *Daugerdas*, and *Greer*. It specifically discusses a scenario where a juror might be dismissed if their past experiences (such as structuring cash transactions) are too similar to the incidents giving rise to the trial.
DOJ-OGR-00009007.jpg
This document is page vi of a legal filing (Case 1:20-cr-00330-PAE, Document 613), filed on February 24, 2022. It is a table of authorities, listing numerous legal cases with their citations and the page numbers where they are referenced in the main document. The cases cited span from 1936 to 2018 and involve various parties in different U.S. federal and state courts.
DOJ-OGR-00009005.jpg
This document is page 4 of a legal filing (Document 613) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on February 24, 2022. It is a 'Table of Authorities' listing various legal precedents (cases) cited in the main document, ranging from 1933 to 2022. Notably, it cites 'Brown v. Maxwell' (2019), a case directly involving the defendant.
DOJ-OGR-00010353.jpg
This legal document is a court opinion from Case 1:20-cr-00330-PAE, filed on April 1, 2022. The court analyzes and rejects the Defendant's (Maxwell's) argument that Juror 50 was biased due to dishonest answers on a jury questionnaire. The court distinguishes this case from precedents involving deliberate deception, crediting Juror 50's explanation that his nondisclosure was an 'inadvertent mistake' resulting from personal distractions and 'skimming' the form.
DOJ-OGR-00009696.jpg
This document is a 'Table of Authorities' from a legal document filed on March 11, 2022, for case 1:20-cr-00330-PAE. It lists numerous legal cases, with decision dates ranging from 1933 to 2022, which are cited as legal precedent in the main filing. Each entry includes the case name, citation, and the page number(s) where it is referenced in the document.
DOJ-OGR-00032410.jpg
This document is a page from a message log containing four phone messages for an individual identified as "JE". Three of the messages, two from Natalie and one from Darren, indicate they were returning JE's calls. A fourth message from Thomas provides a callback number, 305-561-5198, from the "Ferics residence" and is dated 07/26. The calls were received at various times: 12:20 PM, 1:50 PM, 5:45 PM, and one at 2:24 AM.
HOUSE_OVERSIGHT_018697.jpg
This document is a reference list or bibliography page, stamped 'HOUSE_OVERSIGHT_018697', likely from a book or report by Clarisse Thorn (referencing her book 'Confessions of a Pickup Artist Chaser'). The references focus on two main themes: sexual violence/trauma (including orgasm during assault) and the 'Pickup Artist' (PUA) community, citing figures like Neil Strauss, Tyler Durden, and Roissy. The document appears to be part of a larger investigation file, though the text itself does not explicitly mention Jeffrey Epstein.
Phone Call
A message was taken for JE at 2:24 AM from Thomas at the Ferics residence. The message includes a phone number: 305 561 659 5198. The date 07/26 is noted at the bottom.
Information request
Sought info from BOP regarding other correctional officers and charging decisions.
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