Epstein Secrets

mes when even though what I just said about the Supreme Court's view of gag orders and prior restraints and so forth, that in the Don King case, in the Second Circuit, the circuit upheld restrictions there on who could speak, the trial participants. And, again, I would say it's not so much a categorical either/o

nment has demonstrated a rational link between disclosure of the documents and interference with the pending criminal proceedings of Tova Noel and Michael Thomas as well as the criminal prosecution of Nicholas Tartaglione. These are weighty pending criminal proceedings, and the government has clearly explain

mes when even though what I just said about the Supreme Court's view of gag orders and prior restraints and so forth, that in the Don King case, in the Second Circuit, the circuit upheld restrictions there on who could speak, the trial participants. And, again, I would say it's not so much a categorical either/o

nment has demonstrated a rational link between disclosure of the documents and interference with the pending criminal proceedings of Tova Noel and Michael Thomas as well as the criminal prosecution of Nicholas Tartaglione. These are weighty pending criminal proceedings, and the government has clearly explain

’s cellmate was transferred to another facility and he was not assigned a new cellmate. Additionally, on that date, the U.S. Court of Appeals for the Second Circuit unsealed approximately 2,000 pages of documents in civil litigation involving Ghislaine Maxwell, who was later convicted in December 2021 of consp

ified to show that they had been performed. On August 10, at approximately 6:30 a.m., the two SHU staff on duty, CO Tova Noel and Material Handler Michael Thomas, began delivering breakfast to SHU inmates. Noel unlocked the door to Epstein’s SHU tier. When Thomas attempted to deliver breakfast to Epstein

led 04/24/20 Page 1 of 34 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA 19 Cr. 830 (AT) TOVA NOEL and MICHAEL THOMAS, : Defendants. x MEMORANDUM OF LAW OF THE UNITED STATES OF AMERICA IN OPPOSITION TO DEFENDANT MICHAEL THOMAS'S MOTION TO COMPEL GEOFFREY S. BER

on. See Brady v. Maryland, 373 U.S. 83 (1963); Giglio v. United States, 405 U.S. 150 (1972); see also United States v. Coppa, 267 F.3d 132, 139-40 (2d Cir. 2001). Evidence is "material" in this sense only if "its suppression undermines confidence in the outcome of a trial." United States v. Bagley, 473

material." United States v. Persico, 645 F.3d 85, 111 (2d Cir. 2011) (citing cases). With regard to the timing of disclosing material under Giglio, the Second Circuit, in Coppa, rejected the argument that such material should be disclosed when defendants make a 7 EFTA00027318 --- PAGE BREAK --- Case 1:19-cr-0