DOJ-OGR-00022005.pdf

Case 1:19-cr-00830-AT Document 26 Filed 02/10/20 Page 2 of 15 k1u2NoeC kjc 1 (Case called) 2 THE COURT: Good morning. We are here in the matter 3 of the United States v. Tova Noel and Michael Thomas. 4 Would you make your appearance, please. 5 MS. LONERGAN: For the government, Jessica Lonergan. 6 With me at counsel table are my colleagues Nicholas Roos and 7 Rebekah Donaleski. Good morning, your Honor. 8 MR. FOY: May it please the court, your Honor, Jason 9 Foy, for Ms. Tova Noel, standing to my right. Also with me at 10 counsel table is associate counsel Eric Sagara. Good morning, 11 your Honor. 12 MR. SAGARA: Good morning, your Honor. 13 MR. FIGGINS: Good morning your Honor. Montell 14 Figgins on behalf of Michael Thomas, representing my client, 15 who stands to my right. 16 THE COURT: I understand that the defense is 17 requesting that I adjourn the trial because of the volume of 18 discovery. I will hear you on that. 19 MR. FOY: Yes, your Honor. We are asking that the 20 trial date of April 20, 2020, be moved to sometime in October 21 or a date thereafter that's convenient to the court. The 22 reason for the request is because it is necessary in order to 23 provide an adequate and effective assistance of counsel. Why? 24 Yes, because of the voluminous discovery. But also because of 25 the amount of time it is going to take for us to conduct our SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00022005