DOJ-OGR-00021995.jpg

Case 1:19-cr-00830-AT Document 20 Filed 01/27/20 Page 2of2 FOY & SEPLOWITZ trc ATTORNEYS AT LAW PAGE 2 indicated that those video surveillance files will be turned over upon request. Furthermore, SDNY_7549-8118 contains the interviews of approximately 29 employees and 14 inmates. It will be necessary to interview many, if not all the witnesses previously interviewed by the Government. A review of the video surveillance turned over reveals that most of the videos are not date or time stamped. After discussions with the Government, on January 21, 2020, I provided the Government with a flash drive to reproduce the same video surveillance contained in SDNY_00000001 with the date and time stamps. On January 22, 2020, the Government received the flash drive and advised my office that the flash drive was not functioning properly. On January 23, 2020, I forwarded a 1TB hard drive to the Government to provide the requested materials. Based upon representations made by the Government, I expect to receive the hard drive back by January 27, 2020. On January 24, 2020, my office received additional discovery from the Government. The additional discovery increased the global discovery Bates number to 8132. Based upon the volume of discovery received to date, defendant Noel is not able to determine what motions or legal issues she will raise. I anticipate making additional requests for discovery or information, however, I will need significant time to review and digest the discovery to have an appreciation of what materials we do have and what materials we do not have that we are entitled to. I will be prepared to discuss this issue in further detail during our upcoming status conference on January 30, 2020 at 11:00am. Thank you for your thoughtful consideration. Sincerely, FOY & SEPLOWITZ LLC JASON E. FOY jfoy@foyseplowitz.com encl. DOJ-OGR-00021995