The Law Offices of
II II
MONTELL FIGGINS,LLC
www.figginslaw.com
BRANCH OFFICES:
Reply to Newark Office [X]
ASSOCIATES
Kenneth E. Brown, Esq.
Linda Childs. Esq.
January 29, 2020
SENT VIA EMAIL
Assistant United States Attorneys
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
Re: State of NY v Michael Thomas, et al.
Docket No.: I:19-cr-00830
Discovery Request
Dear Ms.
As previously discussed, I am making a formal request pursuant to Rule I6(a)(1)(C) for
any and all reports, memorandums, written statements, photos, videos, and incident reports
created, manufactured or possessed by the United States Inspector General.
Please see U.S. v. Bryan, 868 F.2d 1032 (1989) if you maintain that Mr. Thomas is not
entitled to the requested documents.
Respectfully yours,
/s/ Montell Figgins
Montell Figgins, Esq.
Attorney for Defendant Michael Thomas
cc: Jason Erroy Foy, Esq, Counselfor Defendant Noel via ECF
EFTA00017811