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Case 1:19-cr-00830-AT Document 28 Filed 03/20/20 Page 1 of 1
S ,LLC
17 Academy Street, Suite 305
Newark, New Jersey 07102
Phone: (973) 242-4700
Fax: (973) 242-4701
www.figginslaw.com
BRANCH OFFICES:
th
140 East Ridgewood Avenue 30 Wall Street 8 Floor
Paramus, NJ 07640 New York, NY 1005
Reply to Newark Office [X]
ASSOCIATES
Kenneth E. Brown, Esq.
Linda Childs, Esq.
March 20, 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
Request Extension to File Motion
Dear Judge Torres:
As you are aware, our firm represents the Defendant, Michael Thomas, in the above-
captioned matter. Pursuant to Your Honor’s Order, our firm’s motion to dismiss was due today,
March 20, 2020, however, we are requesting a fourteen (14) day extension in which to file our
motion. Needless to say, the current events with respect to the pandemic affecting the country,
has drastically affected my staff's work hours, as well as my ability to complete this motion
while still managing other issues associated with my business and my family.
In light of the foregoing, the Defendants, by and through th
[…]