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Case 1:19-cr-00830-AT Document 21 Filed 01/27/20 Page2of2 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. As previously noted, I intend on filing a motion for dismissal based on selective prosecution. If successful, this motion will entitle my client to additional discovery beyond what has previously been provided which also pushes the trial timeline beyond April of 2020. My client’s position is also that we are entitled to any and all reports, memorandums, witness statements and investigative reports written, produced or possessed by the inspector general regarding this incident and the Federal Bureau of Prison’s policy regarding written statements and employee conduct. It should be noted, that it took the justice department, the FBI, the inspector general’s office and an assortment of other federal agencies more than 90 days to investigate this matter. Accordingly, it is more than reasonable that it would take the defendant and his counsel, who have less than one percent of the man power and resources of the government, a significantly longer time to accomplish an adequate investigation and review of all the necessary information provided in this case. Respectfully yours, /s/ Montell Figgins Montell Figgins, Esq. Attorney for Defendant Michael Thomas ce: Nicolas Roos, Esq., Counsel for Plaintiff Rebekah Donaleski, Esq., Counsel for Plaintiff Jessica Lonergan, Esq., Counsel for Plaintiff Jason Erroy Foy, Esq, Counsel for Defendant Noel DOJ-OGR-00021997