EFTA00039416.pdf

U.S. Department of Justice United States Attorney Southern District of New York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 March 10, 2020 BY EMAIL Jason E. Foy Fo & Se lowitz LLC Montell Figgins, Esq. 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 is designated as Protected Material 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 Request No. 1-10, 12-13. With respect to your other requests, 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 XX. 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 EFTA00039416