EFTA00023756.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!. Mdlo Building
July 20, 2020
BY EMAIL
Jason E. Foy
Fo & Se lowitz LLC
Re:
United States v. Tom Noel, No. 19 Cr. 830
Dear Mr. Foy:
We write in response to your discovery request letter, dated June 5, 2020. Many of the
items requested in your letter were previously produced to the defendant in discovery, and to the
extent they were not, that is because they were not in the Government's possession. While, as the
Court has already ruled, the Government has no obligation to gather additional documents from
the Bureau of Prisons ("BOP") in response to a discovery request, and you identify no authority to
the contrary in your request, as a courtesy, the Government made a supplemental request to the
BOP for certain records responsive to your requests and that appear to have at least some relevance
to the issues related to this case. Pursuant to that supplemental request, the BOP began producing
records to our Office on or around June 24, 2020, and we are now producing those materials to
you. This letter and the content herein is designated as "Protected Materials" pursuant to the
Protective Order entered in this matter. By contrast, as set forth herein, the Government has not
requested materials not already in its possession that do not seem to have any relevance to this
case, although we are happy to discuss the basis for any such request at your convenience.
Request No. I. Defendant Noel's complete personnel and training file.
The Government has already produced the entirety of the defendant's training and
personnel file in its possession at SDNY_00006228-06273.
The Government received Noel's training record from the BOP on or about June 24, 2020,
and is producing it at SDNY_TN_00020855-020857.
Request No. 2. The BOP and MCC Employee Code of Conduct, Code of Ethics, and
corresponding employee acknowledgement forms for Defendant Noel.
On or about June …

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