DOJ-OGR-00022106.pdf

Case 1:19-cr-00830-AT Document 37 Filed 09/01/20 Page 1 of 1 The Law Offices of MONTELL FIGGINS llc 17 Academy Street, Suite 305 Newark, New Jersey 07102 Phone: (973) 242-4700 Fax: (973) 242-4701 www.figginslaw.com BRANCH OFFICES: 140 East Ridgewood Avenue Paramus, NJ 07640 30 Wall Street 8th Floor New York, NY 1005 Reply to Newark Office [X] Of Counsel Douglas Mitchell, Esq. Linda Childs, Esq. September 1, 2020 SENT VIA ECF Honorable Analisa Torres U.S. Southern District of NY 500 Pearl Street New York, NY 10007 Re: State of NY v Michael Thomas, et al. Docket No.: 1:19-cr-00830 Request To Appear Remotely Dear Hon. Judge Torres: As you are aware, our firm represents the defendant, Michael Thomas, in the above-captioned 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 Thomas 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 DOJ-OGR-00022106