EFTA00027732.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!. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
December 31, 2019
BY FEDEX
Jason E. Foy
Foy & Seplowitz LLC
105 Main Street
Hackensack, NJ 07601
Re:
United States v. Tom Noel, No. 19 Cr. 830
Dear Counsel:
This letter provides discovery pursuant to Rule 16(a) of the Federal Rules of Criminal
Procedure, and seeks reciprocal discovery. This letter and the materials identified herein are
subject to the protective order entered in this case on December 16, 2019, and have been designated
as "Protected Materials" as defined in the order where noted below. Accordingly, the materials
and information identified herein shall not be disclosed to any third party except as set forth in the
protective order.
I.
Disclosure by the Government
Based on your request for discovery in this case, and pursuant to the Government's
obligations under Rule 16(a), enclosed are copies of the following materials, which are being
produced to all defendants and are stamped with the following control numbers:'
Description
Bates Numbers
Classification
Pursuant to
Protective Order
MCC surveillance
footage
from 7/5/2019 to 8/12/20192
SDNY_00000001
Protected Materials
In addition to information provided herein, please note that this Office periodically posts content
on social media platforms including Twitter, Facebook and YouTube. Members of the public may
post comments in response to the Office's postings. We do not control these user-generated
comments, nor do we monitor or regularly review such comments. You may directly access these
social media platforms in the event you believe someone may have posted information relevant to
this case.
2 The Government is producing video surveillance footage of the common area of the Special
Housing Unit for the above-referenced dates. On or about August 10, 2019, the Government seized
06.20.2018
EFTA00027732

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