EFTA00024019

U.S. Department of Justice United States Attorney Southern District of New York The Silvio .1 Mono Building April 14, 2021 BY USAfx 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 additional discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure. 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 'dentified herein shall not be disclosed to any third party or referenced publicly except as set forth in the protective order. Description Bates Numbers Classification Pursuant to Protective Order Arrest documentation and signed SDNY 00017773 — Confidential warrants SDNY 00017775 Documents from the MCC including SDNY 00017776 — Confidential quarters, maps, and rosters SDNY 00017782 SDNY 00017783 — Confidential FBI import forms SDNY 00017822 SDNY 00017823 — Confidential FBI Laboratory examination requests SDNY_00017825 SDNY 00017826 — Confidential FBI process reports SDNY 00017991 SDNY 00017992 — Confidential Witness statements SDNY 00018024 Anonymized index SDNY_00018025 Attorney's Eyes Only Additionally, the Government is producing the following matenals only to your client: 06.20.2018 EFTA00024019 Page 2 Description Bates Numbers Classification Pursuant to Protective Order US Marshals Service Intake and Personal SDNY TN 00020912 — History SDNY TN 00020924 Finally, while we do not agree these materials are required to be produced pursuant to Rule 16, based on your prior request for information, the Government is providing the following information from the Bureau of Prisons ("BOP"): • Since approximately January 1, 2019, in BOP matters that resulted in sustained administrative charges of falsification with regard to log entries, the following disciplinary actions were taken: 2 letters of reprimand; 50 suspensions; 1 demotion; 3 terminations; and 6 resignations/retirements prior to discipline. • The BOP has records of the following, inmate deaths over the last ten years at the MCC and MDC: Inmate Name Register Num DOD Institution 'Death Location Cause of Death Tony McClam 79490-054 9+24/2020 MCC Housing Unit Cardiac enneth Houck 06743-015 5/19/2020 MDC Special Housing Unit Hanging ric Manson 01558-112 10/23/2019 MCC Community Hospital Dru Overdose effre E.stein 6318-054 8/10/2019 MCC C'ommunit Hos • ital Oscar Re oso 0240-019 10/23/2015 MDC Community Hos Fang Xin He '/9018-053 7/19/2012 MDC Mental Health Unit The foregoing information is subject to the protective order. Please contact us with any questions. Very truly yours, AUDREY STRAUSS United States Attorney for the Southern District of New York By: /5/ Assistant United States Attorneys 06.20.2018 EFTA00024020