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Case 1:19-cr-00830-AT Document 20 Filed 01/27/20 Page 1 of 2
105 Main Street 30 Wall Street
Hackensack, NJ 07601 8th Floor
Tel: 201-457-0071 New York, NY 10005
Fax: 201-457-0072 www.foyseplowitz.com Tel: 212-709-8230
January 27, 2020
FILED VIA ECF
Honorable Analisa Torres
United States District Court Judge
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: US v. Tova Noel, et al
Docket # 19 cr. 830 (AT)
Request to Adjourn Trial Date
Dear Judge Torres:
On November 25, 2019, during the initial status conference the Court scheduled the
above referenced criminal action for trial to commence on April 20, 2020. I am
requesting that the trial date be postponed to sometime in October or a date
thereafter that is convenient for the Court.
The adjournment is necessary to ensure that Ms. Noel receives adequate and effective
assistance of counsel. The postponement of the trial will allow for the defense to
review voluminous discovery and conduct a defense investigation of the case.
On November 22, 2019, I informed the Government that I would provide them with
a hard drive during the November 25, 2019 initial status conference. On November
25, 2019, I provided the Government with a hard drive for discovery and the
Government informed the Court that they would produce discovery in 30 days. The
Government forwarded discovery on the hard drive to my office on December 31,
2019. The discovery was received by my office on January 2, 2020. On January 4,
2020, I attempted to review the discovery and I
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