EFTA00021988.pdf

Type: pdf
Source set: data-set-8

Extracted text

U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Motto &Win
New York. New York /0007
March 14, 2020
BY EMAIL
Jason E. Foy
Foy & Seplowitz LLC
Hackensack, NJ 07601
Montell Figgins, Esq.
Law Offices of Montell Fi ins
ewar
Re:
United States v. Tova Noel and Michael Thomas, No. 19 Cr. 830
Dear Counsel:
We write in response to your discovery request letters, dated January 29, 2020. This letter
and the content herein is designated as "Protected Materials" pursuant to the Protective Order
entered in this matter.
Thomas Request. The Government refers to its prior response to this request, as stated at
the November 25, 2019 pretrial conference.
Noel Requests No. 1-10, 12-13. We note, at the outset, that many of these requests are
extremely broad and pertain to information that does not appear to be relevant to the case. To the
extent material called for by these requests is within the Government's possession and subject to
disclosure at this time, the Government has already disclosed such information to you, including
by letter dated January 24, 2020. To the extent these requests call for information that is not
currently in the Government's possession or which is not subject to disclosure, you identify no
legal basis or authority for these requests, and we are not aware of any authority requiring us to
obtain and/or disclose this information.
Noel Request No. 11. The name of the MCC technician referenced in the Government's
previous letter is
Noel Request No. 16.
The Government has already produced the available video
surveillance in its possession for July 23, 2019 for the Special Housing Unit. The Government
attaches hereto two public filings in United States v. Tartaglione, 16 Cr. 832 (KMK), which
reference these issues.
06.20.2018
EFTA00021988

Page 2
Noel Requests No. 14-5, 17-23. These requests, in general terms, call for information about
where particular evidence may be located with…

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