mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00021997.json

{
  "document_metadata": {
    "page_number": "2 of 2",
    "document_number": "21",
    "date": "01/27/20",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00830-AT Document 21 Filed 01/27/20 Page 2 of 2\nThe Law Offices of MONTELL FIGGINS, LLC\n17 Academy Street, Suite 305 Newark, New Jersey 07102 Phone: (973) 242-4700 Fax: (973) 242-4701 www.figginslaw.com BRANCH OFFICES: 140 East Ridgewood Avenue Paramus, NJ 07640 | 30 Wall Street 8th Floor New York, NY 1005 Reply to Newark Office [X]\nASSOCIATES Kenneth E. Brown, Esq. Linda Childs, Esq.\nAs previously noted, I intend on filing a motion for dismissal based on selective prosecution. If successful, this motion will entitle my client to additional discovery beyond what has previously been provided which also pushes the trial timeline beyond April of 2020.\nMy client's position is also that we are entitled to any and all reports, memorandums, witness statements and investigative reports written, produced or possessed by the inspector general regarding this incident and the Federal Bureau of Prison's policy regarding written statements and employee conduct.\nIt should be noted, that it took the justice department, the FBI, the inspector general's office and an assortment of other federal agencies more than 90 days to investigate this matter. Accordingly, it is more than reasonable that it would take the defendant and his counsel, who have less than one percent of the man power and resources of the government, a significantly longer time to accomplish an adequate investigation and review of all the necessary information provided in this case.\nRespectfully yours, /s/ Montell Figgins Montell Figgins, Esq. Attorney for Defendant Michael Thomas\ncc: Nicolas Roos, Esq., Counsel for Plaintiff Rebekah Donaleski, Esq., Counsel for Plaintiff Jessica Lonergan, Esq., Counsel for Plaintiff Jason Erroy Foy, Esq, Counsel for Defendant Noel\nDOJ-OGR-00021997",
  "text_blocks": [
    {
      "type": "printed",
      "content": "The Law Offices of MONTELL FIGGINS, LLC",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "17 Academy Street, Suite 305 Newark, New Jersey 07102 Phone: (973) 242-4700 Fax: (973) 242-4701 www.figginslaw.com BRANCH OFFICES: 140 East Ridgewood Avenue Paramus, NJ 07640 | 30 Wall Street 8th Floor New York, NY 1005 Reply to Newark Office [X]",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "ASSOCIATES Kenneth E. Brown, Esq. Linda Childs, Esq.",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "As previously noted, I intend on filing a motion for dismissal based on selective prosecution. If successful, this motion will entitle my client to additional discovery beyond what has previously been provided which also pushes the trial timeline beyond April of 2020.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "My client's position is also that we are entitled to any and all reports, memorandums, witness statements and investigative reports written, produced or possessed by the inspector general regarding this incident and the Federal Bureau of Prison's policy regarding written statements and employee conduct.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "It should be noted, that it took the justice department, the FBI, the inspector general's office and an assortment of other federal agencies more than 90 days to investigate this matter. Accordingly, it is more than reasonable that it would take the defendant and his counsel, who have less than one percent of the man power and resources of the government, a significantly longer time to accomplish an adequate investigation and review of all the necessary information provided in this case.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Respectfully yours, /s/ Montell Figgins Montell Figgins, Esq. Attorney for Defendant Michael Thomas",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "cc: Nicolas Roos, Esq., Counsel for Plaintiff Rebekah Donaleski, Esq., Counsel for Plaintiff Jessica Lonergan, Esq., Counsel for Plaintiff Jason Erroy Foy, Esq, Counsel for Defendant Noel",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021997",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Montell Figgins",
      "Michael Thomas",
      "Kenneth E. Brown",
      "Linda Childs",
      "Nicolas Roos",
      "Rebekah Donaleski",
      "Jessica Lonergan",
      "Jason Erroy Foy",
      "Noel"
    ],
    "organizations": [
      "The Law Offices of MONTELL FIGGINS, LLC",
      "Federal Bureau of Prison",
      "FBI"
    ],
    "locations": [
      "Newark",
      "New Jersey",
      "Paramus",
      "New York"
    ],
    "dates": [
      "01/27/20",
      "April 2020"
    ],
    "reference_numbers": [
      "1:19-cr-00830-AT",
      "Document 21",
      "DOJ-OGR-00021997"
    ]
  },
  "additional_notes": "The document appears to be a letter from Montell Figgins, Esq. to an unspecified recipient, discussing a legal case involving selective prosecution and requesting additional discovery. The letter is on the letterhead of The Law Offices of MONTELL FIGGINS, LLC."
}