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_. Case 1:19-cr-00830-AT Document 22 Filed 01/28/20 Page 1of3 oe U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007 January 28, 2020 BY ECF The Honorable Analisa Torres United States District Judge Southern District of New York 500 Pearl Street New York, New York 10007 Re: United States vy. Noel and Thomas, 19 Cr. 830 (AT) Dear Judge Torres: The Government respectfully writes in response to the defendants’ letters of January 27, 2020, requesting at least a six-month adjournment of the trial date in the above-captioned case, which is currently scheduled to commence on April 20, 2020. The Government remains prepared to proceed to trial as scheduled. As is set forth more fully below, while the Government has no objection to a brief adjournment of the trial date subject to the Court’s availability, the requested six-month adjournment is both unnecessary and unwarranted. By way of background, as is set forth in the Indictment, the charges in this case relate to a period of just over 14 hours—from approximately 4:00 p.m. on August 9, 2019 to approximately 6:30 a.m. the following day, August 10, 2019. The Government has made three discovery productions—(1) the main production on December 31, 2019; (2) a small supplemental production on January 23, 2020; and (3) a reproduction of video surveillance footage with timestamps on January 24, 2020.' While the December 31, 2019 discovery production consisted of a large number of pages of materials, many of those materials were produced principally in anticipation of defense requests and to help facilitate the very sort of broader investigation the defendants now claim they need to undertake. For example, the Government produced MCC video surveillance for a period of longer than one month (July 5, 2019 to August 12, 2019); count slips for nearly three weeks (July 23, 2019 to August 14, 2019); thirty-minute round reports for more than a month (July 1, 2019 to August 10, 2019); and materials relating to the events of July 23, 2019. Similarly, with respect to defendant Noel, the Government provided in discovery to her only a report from her cellphone, which consists of more than 20,000 pages, very few of which, if any, are relevant to the pending charges. For substantially the same reasons, and as the Court is aware, the ' For the third production, the Government requested additional hard drives from defense counsel. To date, only Noel’s counsel provided a hard drive to the Government, which the Government then loaded and returned to counsel. The Government stands ready to do the same for Thomas as soon as a hard drive is provided. DOJ-OGR- 00021998