Epstein Secrets

p. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

61 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment. The Noel prosecution is pending before the Honorable Analisa Torres, U.S.D.J., with trial scheduled to begin on January 4, 2021. Capone DecL ¶ 9.

p. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

44 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment. The Noel prosecution is pending before the Honorable Analisa Torres, U.S.D.J., with trial scheduled to begin on January 4, 2021. Capone DecL ¶ 9.

p. 2d 423 (S.D.N.Y. 2008) 7, 8 Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., 421 U.S. 168 (1975) 13 Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 SafeCard Sens., Inc. v. S.E.C., 926 F.2d 1197 (D.C. Cir. 1991) 5

78 Case 1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 9 of 30 night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment

United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment. The Noel prosecution is pending before the Honorable Analisa Torres, U.S.D.J., with trial scheduled to begin on January 4, 2021. Capone DecL ¶ 9.

ed such counts. See id. 191 15-24. On November 19, 2019, Noel and Thomas were charged in the Noel Indictment with one count of conspiring to defraud the United States and to make or use a false writing or document, in violation of Title 18, United States Code, Section 371; and five counts as to Noel and three coun

Honorable Richard M. Berman, after which the Court granted the government's motion for remand and denied Epstein's motion for pretrial release. See Noel Indictment(' 10. 6. On July 23, 2019, MCC officers responded to an emergency call and found Epstein on the floor of his cell with a strip of bedsheet around

ted such counts. See id. II 15-24. On November 19, 2019, Noel and Thomas were charged in the Noel Indictment with one count of conspiring to defraud the United States and to make or use a false writing or document, in violation of Title 18, United States Code, Section 371; and five counts as to Noel and three coun

July 23, 2019, MCC officers responded to an emergency call and found Epstein on the floor of his cell with a strip of bedsheet around his neck. See Noel Indictment 1 11. Michael Thomas, a correctional officer at the MCC and one of the defendants in the Noel case, was one of the MCC officials who responded to t

ted such counts. See id. II 15-24. On November 19, 2019, Noel and Thomas were charged in the Noel Indictment with one count of conspiring to defraud the United States and to make or use a false writing or document, in violation of Title 18, United States Code, Section 371; and five counts as to Noel and three coun

July 23, 2019, MCC officers responded to an emergency call and found Epstein on the floor of his cell with a strip of bedsheet around his neck. See Noel Indictment 1 11. Michael Thomas, a correctional officer at the MCC and one of the defendants in the Noel case, was one of the MCC officials who responded to t