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Case 1:19-cr-00830-AT Document 48 Filed 03/10/21 Page 1 of 1
The aw Offices of
TELL F GG
17 Academy Street, Suite 305
I S ,LLC
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]
Of Counsel
Douglas Mitchell, Esq.
Linda Childs, Esq.
March 10, 2021
SENT VIA ECF
Honorable Analisa Torres
U.S. Southern District of NY
500 Pearl Street
New York, NY 10007
Re: USA v Michael Thomas, et al.
Docket No.: 1:19-cr-00830
Request for Emergency Out of State Travel
Your Honor,
This firm represents Defendant, Michael Thomas, in the above-captioned matter. We are
seeking the courts permission for Michael Thomas to take an emergency trip to the State of
Georgia to tend to his sick father.
Kristen McKeown, his pre-trial services officer, does not oppose his emergency travel.
Respectfully yours
/s/ Montell Figgins
Montell Figgins, Esq.
Attorney for Defendant Michael Thomas
cc: Nicolas Roos, Esq., Counsel for Plaintiff
Rebekah Donaleski, Esq., Counsel for Plainti
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