# Document EFTA 02845934



# The Law Offices of MrIKITPI I rinnimc
17 Academy Street, Suite 305 Newark, New Jersey 07102 Phone: (973) 242-4700 Fax: (973)242-4701 www.figginslaw.00m BRANCH OFFICES:

140 East Ridgewood Avenue Paramus, NJ 07640

# Reply to Newark Office [X]
Of Counsel Douglas Mitchell. Esq. Linda Childs. Esq.

# SENT VIA ECF
Honorable Analisa U.S. Southern District of NY 500 Pearl Street New York, NY 10007

30 Wall Street 8" Floor New York, NY 1005

September 1, 2020

Re: State of NY v Michael et al. Docket No.: 1:19-cr-00830 Request To Appear Remotely

Dear Hon. Judge

As you are aware, our firm represents the defendant, Michael M, in the abovecaptioned matter. We are scheduled for a hearing on September 9, 2020. Given the current pandemic, I am not sure if the Court is allowing in-person hearings; however, I am requesting to appear remotely due to the circumstances surrounding COVID-19. Due to my health, I am unfortunately high risk and believe that it is in my best interest to appear remotely.

In light of the foregoing, I respectfully request the Court to allow my appearance via video or telephone.

Respectfully yours,

/s/ Montell Figgins

Montell Figgins, Esq.

Attorney for Defendant Michael

cc: Nicolas Roos, Esq., Counsel for Plaintiff Rebekah Donaleski, Esq., Counsel for Plaintiff Jessica Lonergan, Esq., Counsel for Plaintiff Jason Erroy Foy, Esq, Counsel for Defendant Noel