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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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