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Case 1:19-cr-00830-AT Document 21 Filed 01/27/20 Page 1 of 2
S ,LLC
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 8th Floor
Paramus, NJ 07640 New York, NY 1005
Reply to Newark Office [X]
ASSOCIATES
Kenneth E. Brown, Esq.
Linda Childs, Esq.
January 27, 2020
SENT VIA ECF
Honorable Analisa Torres
U.S. Southern District of NY
500 Pearl Street
New York, NY 10007
Re: State of NY v Michael Thomas, et al.
Docket No.: 1:19-cr-00830
Adjournment Request
Dear Hon. Judge Torres:
Pursuant to the Court’s request, I am making a written request that the April 20, 2020
trial date be adjourned for at least 6 months. Firstly, the government in this matter sent out
discovery on or about December 31, 2019. It was received in my office over the holiday break
when no one was working. Thereafter, there was an issue with me being able to access the drive
containing all of the information proffered by the government because we were given the wrong
password by the government. Accordingly, I have had only about two weeks to review the
voluminous discovery provided.
The discovery ostensibly contains approximately 25,000 documents and hundreds of
hours of video footage. In order to
[…]