ASSOCIATES Kenneth E. Brown, Esq. Linda Childs. Esq.

January 29, 2020

## SENT VIA EMAIL

Assistant United States Attorneys Southern District of New York One Saint Andrew's Plaza New York, NY 10007

> Re: State of NY v Michael Thomas, et al. Docket No.: I:19-cr-00830 Discovery Request

Dear Ms.

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