Case 1:19-cr-00830-AT

Document 29

Filed 03/20/20

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]

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

March 20, 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 Extension to File Motion

Dear Judge Torres:

As you are aware, our firm represents the Defendant, Michael Thomas, in the abovecaptioned matter. Pursuant to Your Honor’s Order, our firm’s motion to dismiss was due today, March 20, 2020, however, we are requesting a fourteen (14) day extension in which to file our motion. Needless to say, the current events with respect to the pandemic affecting the country, has drastically affected my staff's work hours, as well as my ability to complete this motion while still managing other issues associated with my business and my family.

In light of the foregoing, the Defendants, by and through the undersigned, respectfully requests a 14 day extension to file its motion to dismiss.

Respectfully submitted,

/s/ Montell Figgins
Montell Figgins, Esq.
Attorney for Defendant Michael Thomas

MF/sf
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