Epstein Secrets

Case 1:19-cr-00830-AT Document 56 Filed 05/2 USA 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America v. Michael Thomas, Defendant. TO: MICHAEL THOMAS DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 5/25/2021 Deferred Prosecution Agreement 19 Cr. 830 (AT) O

rther prosecution will be instituted in this District for the above offenses. Nothing in this Agreement shall be interpreted to preclude the BOP or the DOJ-OIG from taking any administrative action against you, including suspension or termination of employment, based on the facts alleged in the Indictment,

Case 1:19-cr-00830-AT Document 56 Filed 05/2 USA 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America v. Michael Thomas, Defendant. TO: MICHAEL THOMAS DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 5/25/2021 Deferred Prosecution Agreement 19 Cr. 830 (AT) O

rther prosecution will be instituted in this District for the above offenses. Nothing in this Agreement shall be interpreted to preclude the BOP or the DOJ-OIG from taking any administrative action against you, including suspension or termination of employment, based on the facts alleged in the Indictment,

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

ecords and prior work schedules; and reports and notes of witness interviews prepared by agents from the Federal Bureau of Investigation ("FBI") and the DOJ-OIG who were participating in the investigation.2 Subsequently, the Government made three additional discovery productions, much more limited in scope.