I I II The Law Offices of MONTELL FIGGINS,LLC www.figginslaw.com BRANCH OFFICES: Reply to Newark Office [X] ASSOCIATES Kenneth E. Brown, Esq. Linda Childs. Esq. SENT VIA EMAIL Assistant United States Attorneys Southern District of New York One Saint Andrew's Plaza New York, NY 10007 Dear Ms. January 29, 2020 Re: State of NY v Michael Thomas, et al. Docket No.: I:19-cr-00830 Discovery Request 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, Counsel for Defendant Noel via ECF EFTA00017811