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he United States in violation of 18 U.S.C. § 1001(aX3). ECF No. 1. The indictment alleges that Thomas, in his capacity as a correctional officer at the Metropolitan Correctional Center (the "MCC"), along with another officer, co-Defendant Tova Noel, submitted several false "count slips" on the night of August 9, 2019 and the morni
re, and (2) the constitutional guarantee of due process as expressed by the Supreme Court's decisions in Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972). Motion at 1. I. Legal Standards A. Rule 16 Rule 16 requires the Government to "permit the defendant to ins
he United States in violation of 18 U.S.C. § 1001(aX3). ECF No. 1. The indictment alleges that Thomas, in his capacity as a correctional officer at the Metropolitan Correctional Center (the "MCC"), along with another officer, co-Defendant Tova Noel, submitted several false "count slips" on the night of August 9, 2019 and the morni
re, and (2) the constitutional guarantee of due process as expressed by the Supreme Court's decisions in Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972). Motion at 1. I. Legal Standards A. Rule 16 Rule 16 requires the Government to "permit the defendant to ins
he United States in violation of 18 U.S.C. § 1001(aX3). ECF No. 1. The indictment alleges that Thomas, in his capacity as a correctional officer at the Metropolitan Correctional Center (the "MCC"), along with another officer, co-Defendant Tova Noel, submitted several false "count slips" on the night of August 9, 2019 and the morni
re, and (2) the constitutional guarantee of due process as expressed by the Supreme Court's decisions in Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972). Motion at 1. I. Legal Standards A. Rule 16 Rule 16 requires the Government to "permit the defendant to ins
he United States in violation of 18 U.S.C. § 1001(aX3). ECF No. 1. The indictment alleges that Thomas, in his capacity as a correctional officer at the Metropolitan Correctional Center (the "MCC"), along with another officer, co-Defendant Tova Noel, submitted several false "count slips" on the night of August 9, 2019 and the morni
Page: EFTA00022186 →re, and (2) the constitutional guarantee of due process as expressed by the Supreme Court's decisions in Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972). Motion at 1. I. Legal Standards A. Rule 16 Rule 16 requires the Government to "permit the defendant to ins
Page: EFTA00022187 →Entities connected to both Metropolitan Correctional Center and Giglio

Jeffrey Epstein
PERSONFederal Bureau of Prisons
ORGANIZATION
Department of Justice
ORGANIZATIONSpecial Housing Unit
ORGANIZATION
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
United States
LOCATIONthe Southern District
LOCATION
New York
LOCATION
Prince Andrew
PERSON
George W. Bush
PERSONLeon Black
PERSON
Julie K. Brown
PERSON
Donald Trump
PERSON
Geoffrey S. Berman
PERSON
Alfredo Rodriguez
PERSON
Brady
PERSON
South
LOCATION
Southern District of New York
ORGANIZATIONSouthern District
LOCATION