EFTA00025239.pdf

"Montell Figgins, Esq... Re: United States v. Michael Thomas... Dear Counsel"

"GEOFFREY S. BERMAN United States Attorney for the Southern District of New York"

"Photographs of Jeffrey's Epstein's cell; Epstein general BOP records"

"Inmate-5 stated that Noel came by around 10 to do the count on the evening of August 9, 2019."

"The Government is unaware of any other Brady material regarding your client, but will provide timely disclosure"

"Personnel records for Noel and Thomas; Prior work schedule for Noel and Thomas"

"Personnel records for Noel and Thomas; Noel came by around 10 to do the count"

"Computer analysis for computers used by Noel and Thomas; Personnel records for Noel and Thomas"

"Inmate-11 stated that... The male black stayed by the door"

"Inmate-11 stated that... the female black walked through the tier but did not walk all the way in."

"materials from Inmate-2 include a statement which could constitute Brady, however, the Court has directed the Government to withhold these materials"

"On or about August 10, 2019, the Government seized the contents of the MCC's video surveillance system... Death reports and photos"

"Inmate-5 stated that Noel came by... Disclosure by the Defendant... The Government is unaware of any other Brady material regarding your client"