Key details from the image:

*   Law firm: The Law Offices of Montell Figgins, LLC
*   Website: www.figginslaw.com
*   Branch Offices exist (locations blacked out)
*   "Reply to Newark Office [X]" is noted.
*   Associates include: Kenneth E. Brown, Esq., Linda Childs. Esq.

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.
Attorneyfor Defendant Michael Thomas

cc: Jason Erroy Foy, Esq, Counselfor Defendant Noel via ECF

EFTA00017811