Epstein Secrets

d Materials Anonymized Index (Produced Under Separate Cover) SDNY_00008123 Attorney's Eyes' Only The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny. The Government wishes to bring your attention to the following statements, which could constitute

records, open the file and when prompted for a password, click on "read only." 06.20.2018 EFTA00027734 --- PAGE BREAK --- Page 4 Pay stubs for Tova Noel SDNY_TN_00020801- SDNY_TN_00020826 Arrest photo of Tova Noel SDNY_TN_00020827 CLEAR report SDNY_TN_00020828- SDNY_TN_00020849 BOP email records

produce these materials if and when the Court orders their production. Beyond the above materials, to date, the Government is unaware of any other Brady material regarding your client, but will provide timely disclosure if any such material comes to light. The Government will provide material under G

USION 29 EFTA00031264 --- PAGE BREAK --- TABLE OF AUTHORITIES Cases 27 passim Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479 (S.D.N.Y. 2010) Brady v. Maryland, 373 U.S. 83 (1963) Color of Change v. United States Dep't of Homeland Sec., 325 F. Supp. 3d 447 (S.D.N.Y. 2018) 27 Dep't of Interior

suicide (Mot. 6); and (iv) reports, statistics, and documents related to purported staffing issues, supervisory lapses, and the application of BOP Tova Noel did not file any pretrial motions, and has not joined in Thomas's pretrial motions. See Fed. R. Crim. P. 12(c)(3) ("If a party does not meet the dea

respects. STATEMENT OF FACTS I. The Indictment Indictment 19 Cr. 830 (AT) (the "Indictment") was filed on November 19, 2019, charging defendants Tova Noel and Michael Thomas in six counts: (i) conspiring to defraud the United States and to make or use a false writing or document, in violation of Title

0-AT Document 35 Filed 04/24/20 Page 3 of 34 TABLE OF AUTHORITIES 27 passim Cases Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479 (S.D.N.Y. 2010) Brady v. Maryland, 373 U.S. 83 (1963) Color of Change v. United States Dep't of Homeland Sec., 325 F. Supp. 3d 447 (S.D.N.Y. 2018) 27 Dept of Interior

suicide (Mot. 6); and (iv) reports, statistics, and documents related to purported staffing issues, supervisory lapses, and the application of BOP Tova Noel did not file any pretrial motions, and has not joined in Thomas's pretrial motions. See Fed. R. Crim. P. 12(c)(3) ("If a party does not meet the dea

AGE BREAK --- Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 13 of 34 demand for it. 267 F.3d at 146. The court held that as a general rule, Brady and its progeny do not require immediate disclosure of all impeachment material upon a defendant's request. Id. It found that the time required for

cr-00830-AT Document 36 Filed 06/09/20 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, -against- TOVA NOEL and MICHAEL THOMAS, Defendants. USDC SDNY DOCUMENT ELECTRONICALLY Fli i) DOC #: DATE FILED: 6/9/2020 19 Cr. 830-2 (AT) ORDER ANALISA TORRE

16 of the Federal Rules of Criminal Procedure, 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 t