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Case 1:19-cr-00830-AT Document 22 Filed 01/28/20 Page 1 of 3
U.S. Department of Justice
[Type text]
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 v. 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. 1 While the December 31, 2019 discovery production consisted of a large
number of pages
[…]