DOJ-OGR-00022028.pdf

Case 1:19-cr-00830-AT Document 33 Filed 04/09/20 Page 5 of 38 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, -against- TOVA NOEL and MICHAEL THOMAS Defendants. 19 Cr. 830-2(AT) Oral Argument Requested MOTION OF MICHAEL THOMAS TO COMPEL DISCOVERY INTRODUCTION Defendant, Michael Thomas, through his counsel, hereby moves for an order compelling the government to produce information in its possession or accessible to it from other agencies allied with the prosecution, concerning investigations and other materials relating to the facts alleged in the indictment, including but not limited to such documents that relate to the investigation into the death of Jeffrey Epstein, that is (a) material to the preparation under Fed. R. Crim. P. 16, and/or (b) exculpatory, inculpatory, or impeachment information discoverable under the Brady-Giglio doctrine. The information requested in this motion has been previously requested by the defense in a letter dated January 29, 2020 from the Office of the United States Attorney, Southern District of New York. (See Exhibit A.) Through counsel from said office, the request has been denied, with government prosecutors referring defense counsel to their in-court statements made on November 25, 2019. (See Exhibit B.) 1 DOJ-OGR-00022028