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Case 1:19-cr-00830-AT Document 21 Filed 01/27/20 Pagelof2 yp 1he Law Offices of wall MONTELL FIGGINS, ic 17 Academy Street, Suite 305 Newark, New Jersey 07102 Phone: (973) 242-4700 Fax: (973) 242-4701 www. figginslaw.com BRANCH OFFICES: 140 East Ridgewood Avenue 30 Wall Street 8" Floor Paramus, NJ 07640 New York, NY 1005 Reply to Newark Office [X] ASSOCIATES Kenneth E. Brown, Esq. Linda Childs, Esq. January 27, 2020 SENT VIA ECF Honorable Analisa Torres U.S. Southern District of NY 500 Pearl Street New York, NY 10007 Re: State of NY v Michael Thomas, et al. Docket No.: 1:19-cr-00830 Adjournment Request Dear Hon. Judge Torres: Pursuant to the Court’s request, I am making a written request that the April 20, 2020 trial date be adjourned for at least 6 months. Firstly, the government in this matter sent out discovery on or about December 31, 2019. It was received in my office over the holiday break when no one was working. Thereafter, there was an issue with me being able to access the drive containing all of the information proffered by the government because we were given the wrong password by the government. Accordingly, I have had only about two weeks to review the voluminous discovery provided. The discovery ostensibly contains approximately 25,000 documents and hundreds of hours of video footage. In order to effectively represent my client, I will need at least an additional 60 days to review the discovery and discuss it with my client. Thereafter, I will still need to conduct an investigation based on the information and witness statements detailed in the discovery. Such an undertaking will take at the minimum another 60 days. As the Court can see, it will take me 90 days or more before I am in a position to know what additional discovery may be needed or what motions are appropriate. Additionally, this timeline doesn’t even account for issues regarding subpoenas, requests for additional discovery and attempting to locate witnesses or hire experts. DOJ-OGR-00021996