Thomas
PersonRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
organization
GOVERNMENT
|
Legal representative |
7
|
3 | |
|
person
Noel
|
Co defendants |
7
|
3 | |
|
organization
The government
|
Legal representative |
6
|
2 | |
|
person
government prosecutors
|
Legal representative |
5
|
1 | |
|
person
United States Government
|
Adversarial |
5
|
1 | |
|
person
United States Government
|
Legal representative |
5
|
1 | |
|
person
United States (The Government)
|
Legal representative |
5
|
1 | |
|
person
Noel
|
Professional |
5
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| N/A | Legal proceeding | A criminal investigation and prosecution where the defendant, Thomas, is seeking discovery materi... | N/A | View |
| 2021-05-25 | Court hearing | A proposed hearing date for the entry of the deferred prosecution agreements, to be held by video... | Video conference | View |
| 2020-04-20 | Trial | Scheduled commencement date for the trial in the case of United States v. Noel and Thomas. | Southern District of New York | View |
| 2020-04-09 | Legal filing | A motion for discovery was filed on behalf of Defendant Thomas, requesting reports and other info... | Court | View |
| 2020-04-09 | Legal filing | Thomas filed a motion seeking an order from the Court to compel the Government to produce documents. | N/A | View |
| 2020-04-01 | Communication | The Government sent a letter explaining its position on information requests. | N/A | View |
| 2020-01-24 | Legal proceeding | The Government provided a reproduction of video surveillance footage with timestamps. | N/A | View |
| 2020-01-23 | Legal proceeding | The Government made a small supplemental discovery production. | N/A | View |
| 2019-12-31 | Legal proceeding | The Government made its main discovery production to the defense. | N/A | View |
| 2019-08-09 | Falsification of records | Defendants admitted to willfully and knowingly completing materially false count and round slips. | Special Housing Unit of the... | View |
| 2019-01-01 | Crime | Conduct for which Mr. Thomas is criminally charged, which was allegedly caused by rampant staffin... | MCC | View |
| 1994-01-01 | Court case | Thomas v. I.N.S., 35 F.3d 1332 (9th Cir. 1994), which enforced a cooperation agreement against th... | 9th Cir. | View |
DOJ-OGR-00021083.jpg
This legal document, a page from a court filing dated February 28, 2023, presents a series of case law citations to support the legal argument that a plea agreement made by an Assistant U.S. Attorney (AUSA) binds the entire United States government. The cited cases establish that the U.S. government is considered a single entity across all districts, and therefore, an agreement made by one of its attorneys in one location (e.g., West Virginia) is enforceable against federal prosecutors in another (e.g., South Dakota).
DOJ-OGR-00022122.jpg
This legal filing from the U.S. Attorney for the Southern District of New York, dated May 21, 2021, informs Judge Analisa Torres about deferred prosecution agreements reached with defendants Noel and Thomas. The defendants, employees of the Bureau of Prisons, have admitted to falsifying records at the Metropolitan Correctional Center in August 2019 and, in exchange for deferred prosecution, will cooperate with an OIG investigation and complete 100 hours of community service. The government requests a court hearing for May 25, 2021, to finalize these agreements.
DOJ-OGR-00022096.jpg
This is the concluding page of a legal document filed on April 24, 2020, by the office of United States Attorney Geoffrey S. Berman. The document argues that the defendant Thomas's motion to compel discovery for a selective prosecution defense should be denied because the defendant failed to meet the required 'rigorous standard'. The filing cites several legal precedents to support the argument that courts routinely prevent defendants from questioning the government's motives for prosecution at trial.
DOJ-OGR-00022093.jpg
This legal document is a court filing from April 24, 2020, discussing a motion by an individual named Thomas. The court denies Thomas's request for discovery related to his claim of selective or discriminatory prosecution, finding he has not met the high burden of proof required. The court dismisses Thomas's comparison to a 2005/2006 incident involving other officers, stating it is not relevant because Thomas is charged with making false statements, not with failing to conduct counts.
DOJ-OGR-00022086.jpg
This legal document is a filing by the Government arguing against a discovery request from a defendant named Thomas. The Government contends that it is not required to produce records from the Bureau of Prisons (BOP) because the BOP was not part of the prosecution team or involved in a 'joint investigation'. The document distinguishes the roles of the prosecution (U.S. Attorney's Office, FBI, DOJ-OIG) from the BOP, noting the Government obtained BOP records via subpoena and was not involved in the BOP's internal investigation into Epstein's suicide.
DOJ-OGR-00022082.jpg
This legal document is a filing by the Government arguing against a motion from a defendant named Thomas. The Government contends it is not required to produce documents from separate investigations conducted by the Bureau of Prisons (BOP) or other federal agencies into the death of Jeffrey Epstein, because those agencies are not part of the prosecution team and the materials are not in the prosecution's possession.
DOJ-OGR-00022079.jpg
This legal document, filed on April 24, 2020, is a discussion from the prosecution arguing against the defense strategy of a defendant named Thomas. The prosecution contends that Thomas's plan to argue for acquittal based on being overworked and understaffed at the MCC, with rampant falsification of records within the BOP, is not a valid legal defense. The document cites case law (United States v. Carr) to support the argument that such excuses do not negate the elements of the crime and that allowing this defense would encourage jury nullification.
DOJ-OGR-00022076.jpg
This legal document is a filing by the Government arguing that it has fulfilled its discovery obligations under Brady, Giglio, and Rule 16. The Government details the materials it has produced, including records surrounding Epstein's suicide and employee files for Noel and Thomas, and cites legal precedents from the Southern District of New York to support its position that the defendant's motion to compel further discovery should be denied.
DOJ-OGR-00022075.jpg
This legal document, filed on April 24, 2020, is a portion of a government motion arguing that it has fulfilled its discovery obligations to a defendant named Thomas. The government asserts it has complied with legal standards, including Rule 16 and the Brady rule, by providing substantial evidence, such as hundreds of hours of video surveillance, well in advance of the trial.
DOJ-OGR-00022073.jpg
This legal document is a filing by the Government arguing against a motion filed by an individual named Thomas on April 9, 2020. Thomas is seeking to compel the Government to produce a wide range of documents related to the investigation into Jeffrey Epstein's death, including the Inspector General's report, Bureau of Prisons (BOP) records, and disciplinary files for MCC employees. The Government asserts that Thomas is not entitled to these materials and that his motion should be denied by the Court.
DOJ-OGR-00022067.jpg
This document is page 5 of a 34-page legal filing (Document 35 in case 1:19-cr-00830-AT), filed on April 24, 2020. It serves as a table of authorities, listing numerous legal cases cited within the main document, such as United States v. Payne and United States v. Pelullo. Each entry includes the full legal citation and the page number(s) where the case is referenced in the filing.
DOJ-OGR-00022043.jpg
This document is the concluding page of a legal motion (Document 33, Case 1:19-cr-00830-AT) filed on April 9, 2020. Attorney Montell Figgins, representing defendant Michael Thomas, requests that the court grant their Motion to Compel, arguing that requested reports are subject to Brady disclosure and should be produced within 45 days of the court's order.
DOJ-OGR-00022034.jpg
This document is a legal motion filed on April 9, 2020, in a criminal case on behalf of Defendant Thomas. The defense requests the court to compel the prosecution to turn over various documents and reports, arguing they contain exculpatory evidence under Rule 16 and Brady-Giglio. The motion claims the defendant's alleged criminal conduct was a result of widespread practices and policies within the Bureau of Prisons (BOP) and that the government has unfairly refused to disclose this relevant information.
DOJ-OGR-00021998.jpg
This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Analisa Torres, dated January 28, 2020. The prosecution argues against a six-month trial adjournment requested by the defendants, Noel and Thomas, stating that the delay is unnecessary and unwarranted. The letter details the extensive discovery materials already provided to the defense and affirms the government's readiness to proceed with the trial scheduled for April 20, 2020.
DOJ-OGR-00021964.jpg
This document is a court transcript from December 16, 2019, detailing a hearing about the pretrial release conditions for defendants Thomas and Noel. The conditions discussed include restrictions on alcohol use and mandatory mental health evaluation, as directed by pretrial services. An attorney, Mr. Foy, objects to one of the conditions, stating it was not part of a prior agreement on the terms of release.
DOJ-OGR-00021963.jpg
This is a court transcript from December 16, 2019, detailing a hearing for defendants Thomas and Noel. Defendant Thomas pleads not guilty, after which Mr. Roos outlines the nearly identical bail conditions for both defendants, which include a $100,000 bond and specific travel restrictions within New York and New Jersey.
Response to information requests
A letter dated April 1, 2020, from the Government explaining that responsive information had been produced and that there was no legal basis for requests for items not in its possession or not subject to disclosure.
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