EFTA00017811
This is a legal discovery request letter from Montell Figgins, attorney for defendant Michael Thomas, to Assistant United States Attorneys in the Southern District of New York.
Dated January 29, 2020, this formal letter requests all reports, memorandums, and other materials from the United States Inspector General regarding the case State of NY v Michael Thomas. The attorney cites Rule 16(a)(1)(C) and references a legal precedent (U.S. v. Bryan) to support the defendant's right to these documents. The letter is cc'd to Jason Erroy Foy, counsel for another defendant named Noel.
Key Highlights
- •Formal discovery request under Rule 16(a)(1)(C) for Inspector General materials
- •Case: State of NY v Michael Thomas, Docket No. 1:19-cr-00830
- •Request includes reports, photos, videos, and incident reports
- •Cites U.S. v. Bryan, 868 F.2d 1032 (1989) as legal precedent
- •Defense attorney Montell Figgins represents Michael Thomas
- •Copy sent to Jason Erroy Foy, counsel for defendant Noel
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EFTA00017811
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Page 1 - EFTA00017811
I I II The Law Offices of MONTELL FIGGINS,LLC www.figginslaw.com BRANCH OFFICES: Reply to Newark Office [X] ASSOCIATES Kenneth E. Brown, Esq. Linda Childs. Esq. SENT VIA EMAIL Assistant United States Attorneys Southern District of New York One Saint Andrew's Plaza New York, NY 10007 Dear Ms. January 29, 2020 Re: State of NY v Michael Thomas, et al. Docket No.: I:19-cr-00830 Discovery Request As previously discussed, I am making a formal request pursuant to Rule I6(a)(1)(C) for any and all reports, memorandums, written statements, photos, videos, and incident reports created, manufactured or possessed by the United States Inspector General. Please see U.S. v. Bryan, 868 F.2d 1032 (1989) if you maintain that Mr. Thomas is not entitled to the requested documents. Respectfully yours, /s/ Montell Figgins Montell Figgins, Esq. Attorney for Defendant Michael Thomas cc: Jason Erroy Foy, Esq, Counsel for Defendant Noel via ECF EFTA00017811
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