FOY & SEPLOWITZ LLC

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person TOVA NOEL
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066.pdf

A letter from attorney Jason E. Foy to Judge Analisa Torres dated January 5, 2022, regarding the case US v. Tova Noel. Following the dismissal of all criminal charges against Tova Noel on January 3, 2022, the letter requests a court order to compel the NYPD to release Noel's firearm, which she had surrendered as a condition of her release in 2019. The NYPD property clerk had previously refused to return the item without a specific court order.

Legal correspondence / letter to judge
2025-12-26

017.pdf

This document is a transcript of a court conference held on November 25, 2019, regarding the case of United States v. Tova Noel and Michael Thomas, the correctional officers charged in connection with Jeffrey Epstein's death. The proceedings cover the schedule for discovery production (including hundreds of hours of video), the setting of a trial date for April 20, 2020, and arguments regarding the relevance of an ongoing DOJ Inspector General report into the Bureau of Prisons. The court also addressed bail conditions, granting a travel restriction modification for Noel and an extension for Thomas to secure cosigners, but denying Noel's request to keep her personal firearm at home due to safety concerns for pretrial services officers.

Court transcript (conference)
2025-12-26

EFTA00027732.pdf

This document is a discovery letter from the U.S. Department of Justice to the attorney for Tova Noel, a correctional officer charged in connection with Jeffrey Epstein's death. It lists extensive materials being provided to the defense, including MCC surveillance footage, computer analysis, phone records, and internal logs from the dates surrounding Epstein's death (August 9-10, 2019). The letter also discloses Brady material consisting of statements from inmates regarding the timeline of officer rounds on the night Epstein died, contradicting or clarifying the official timeline.

Legal correspondence / discovery letter
2025-12-25

EFTA00026450.pdf

This document is an email dated June 5, 2020, from attorney Jason Foy of Foy & Seplowitz LLC to opposing counsel regarding the case 'US v. Tova Noel'. The email attaches a supplemental discovery demand and asks for an anticipated timeline for a response.

Email
2025-12-25

EFTA00023768.pdf

This document is a discovery request letter from attorney Jason E. Foy, representing Tova Noel (a guard charged in relation to Jeffrey Epstein's death), to the US Attorney's Office. The letter demands 31 specific items, including Noel's personnel files, SHU logs from the time of Epstein's death (August 2019), surveillance records of broken cameras, and internal memos regarding Epstein's need for a cellmate. It also notably asks for the identity of the author of a specific 4Chan message and records related to other inmate deaths at the MDC.

Legal correspondence / discovery request
2025-12-25

EFTA00021988.pdf

A discovery response letter from the U.S. Attorney's Office (SDNY) to defense counsel for Tova Noel and Michael Thomas, the guards charged in connection with Jeffrey Epstein's death. The letter identifies specific video surveillance files and timestamps from August 9-10, 2019, documenting Epstein's movements (including a phone call) and the defendants' computer usage at the desk. It also addresses requests regarding an MCC technician and video from July 23, 2019.

Legal correspondence / discovery response letter
2025-12-25

EFTA00018948.pdf

This document is a discovery response letter from the U.S. Attorney's Office (SDNY) to defense counsel for Tova Noel and Michael Thomas, dated March 14, 2020. It provides specific timestamps and video file identifications from MCC surveillance footage on the night of Jeffrey Epstein's death (August 9-10, 2019), including times Epstein left his cell for a phone call and times the defendants were at their desk using computers. It also identifies an MCC technician named Hughwon Daniel.

Legal correspondence / discovery response letter
2025-12-25

EFTA00018834.pdf

This document is an email chain from February 26, 2021, involving attorney Jason Foy of Foy & Seplowitz LLC. The correspondence concerns the case 'US v. Noel' (referring to Tova Noel, one of the guards charged in connection with Jeffrey Epstein's death). Foy confirms sending a 'Deferred Prosecution Submission' via FedEx and subsequently provides electronic copies of the submission and exhibits to the redacted recipients.

Email chain
2025-12-25

DOJ-OGR-00022150.jpg

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.

Legal letter/correspondence
2025-11-20

DOJ-OGR-00021994.jpg

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.

Legal correspondence / court filing (motion to adjourn)
2025-11-20
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