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Case 1:19-cr-00830-AT Document35 Filed 04/24/20 Page 10 of 34 written statements, photos, videos, and incident reports created, manufactured or possessed by the United States Inspector General.” Noel’s January 29 letter sought materials related to the MCC video surveillance system and additional surveillance video, as well as assistance locating particular information in the surveillance video footage that the Government had previously produced in discovery. At the pretrial conference the following day, Thomas, through counsel, renewed his request for “whatever investigation was done and whatever information there is that is discoverable with respect to the Inspector General’s report.” (Conf. Tr., Jan. 30, 2020, at 6, 9). The Court directed Thomas to file a motion formalizing his request. (Id. at 9).° The Government responded to the defendants’ discovery requests by letter dated March 14, 2020. As for Thomas’s request for materials related to any forthcoming Inspector General’s report, the Government referred Thomas to its prior response as stated at the November 25, 2019 pretrial conference. With respect to Noel’s requests for additional materials related to the MCC video surveillance system, the Government explained that to the extent such materials were in the Government’s possession and currently subject to disclosure, they had already been produced. In addition, the Government provided additional information answering certain of Noel’s questions, including video timestamps to assist with review of the surveillance footage. On March 27, 2020, Thomas submitted another discovery request to the Government, seeking, among other things, information from the BOP regarding other correctional officers and information about the Government’s charging decisions. The Government responded by letter > Thomas, through counsel, previewed that he would also likely file a motion to dismiss the indictment based on “selective prosecution.” (Conf. Tr., Jan. 30, 2020 at 6). The deadline for filing motions, which was extended at counsel’s request, has passed, and Thomas has failed to timely file a motion to dismiss. DOJ-OGR-00022072