DOJ-OGR-00021994.pdf

Case 1:19-cr-00830-AT Document 20 Filed 01/27/20 Page 1 of 2 FOY & SEPLOWITZ attorneys at law 105 MAIN STREET HACKENSACK, NJ 07601 TEL: 201-457-0071 FAX: 201-457-0072 WWW.FOYSEPLOWITZ.COM 30 WALL STREET 8TH FLOOR NEW YORK, NY 10005 TEL: 212-709-8230 January 27, 2020 FILED VIA ECF Honorable Analisa Torres United States District Court Judge Southern District of New York 500 Pearl Street New York, NY 10007 Re: US v. Tova Noel, et al Docket # 19 cr. 830 (AT) Request to Adjourn Trial Date Dear Judge Torres: On November 25, 2019, during the initial status conference the Court scheduled the above referenced criminal action for trial to commence on April 20, 2020. I am requesting that the trial date be postponed to sometime in October or a date thereafter that is convenient for the Court. The adjournment is necessary to ensure that Ms. Noel receives adequate and effective assistance of counsel. The postponement of the trial will allow for the defense to review voluminous discovery and conduct a defense investigation of the case. On November 22, 2019, I informed the Government that I would provide them with a hard drive during the November 25, 2019 initial status conference. On November 25, 2019, I provided the Government with a hard drive for discovery and the Government informed the Court that they would produce discovery in 30 days. The Government forwarded discovery on the hard drive to my office on December 31, 2019. The discovery was received by my office on January 2, 2020. On January 4, 2020, I attempted to review the discovery and I could not access it because the Government provided the incorrect password to get access. On January 6, 2020, I was provided with the correct password and gained my first access to the discovery. The discovery contained in the initial production is 877GB of materials. The 877GB of materials contains up to 8118 Bates of global discovery and up to 20,853 Bates of individual discovery. In folder marked SDNY_00000001, there is video surveillance capturing 3 separate cameras from July 5, 2019 thru August 12, 2019. Each date allegedly contains the 24-hour period for each day, from each camera, and in 1-hour increments per individual file. Note, that there is video surveillance in the Government's possession that has not been turned over, however, the Government DOJ-OGR-00021994