DOJ-OGR-00021998.jpg
900 KB
Extraction Summary
3
People
6
Organizations
3
Locations
6
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
900 KB
Summary
This legal document is a letter from the U.S. Attorney for the Southern District of New York to Judge Analisa Torres, dated January 28, 2020. The prosecution argues against a six-month trial adjournment requested by the defendants, Noel and Thomas, stating that the delay is unnecessary and unwarranted. The letter details the extensive discovery materials already provided to the defense and affirms the government's readiness to proceed with the trial scheduled for April 20, 2020.
People (3)
| Name | Role | Context |
|---|---|---|
| Analisa Torres | United States District Judge |
The recipient of the letter, addressed as 'The Honorable Analisa Torres' and 'Dear Judge Torres'.
|
| Noel | Defendant |
A defendant in the case 'United States v. Noel and Thomas'. Mentioned in relation to discovery materials provided by ...
|
| Thomas | Defendant |
A defendant in the case 'United States v. Noel and Thomas'. The government is ready to provide discovery to his counsel.
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| U.S. Department of Justice | Government agency |
Appears in the letterhead of the document.
|
| United States Attorney, Southern District of New York | Government agency |
The sender of the letter.
|
| Southern District of New York | Judicial district |
The jurisdiction of the court where the case is being heard.
|
| The Government | Government agency |
Used throughout the document to refer to the prosecution (the U.S. Attorney's office).
|
| The Court | Judicial body |
Refers to the United States District Court for the Southern District of New York.
|
| MCC | Correctional facility |
Mentioned in the context of 'MCC video surveillance' provided in discovery.
|
Timeline (6 events)
2019-08-09
Start of the period to which the charges in the indictment relate, beginning at approximately 4:00 p.m.
2019-08-10
End of the period to which the charges in the indictment relate, ending at approximately 6:30 a.m.
2019-12-31
The Government made its main discovery production to the defense.
2020-01-23
The Government made a small supplemental discovery production.
2020-01-24
The Government provided a reproduction of video surveillance footage with timestamps.
2020-04-20
Scheduled commencement date for the trial in the case of United States v. Noel and Thomas.
Southern District of New York
Locations (3)
| Location | Context |
|---|---|
|
The address of the United States Attorney, Southern District of New York.
|
|
|
The address of the United States District Judge, Southern District of New York.
|
|
|
The city where the U.S. Attorney's office and the court are located.
|
Relationships (3)
The Government is prosecuting defendant Noel in the case 'United States v. Noel and Thomas' and has provided discovery materials to her counsel.
The Government is prosecuting defendant Thomas in the case 'United States v. Noel and Thomas' and is ready to provide discovery materials to his counsel.
Full Extracted Text
Complete text extracted from the document (2,747 characters)
Case 1:19-cr-00830-AT Document 22 Filed 01/28/20 Page 1 of 3
U.S. Department of Justice
United States Attorney
Southern District of New York
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
One Saint Andrew’s Plaza
New York, New York 10007
January 28, 2020
BY ECF
The Honorable Analisa Torres
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007
Re: United States v. Noel and Thomas,
19 Cr. 830 (AT)
19 Cr. 830 (AT)
Dear Judge Torres:
The Government respectfully writes in response to the defendants’ letters of January 27, 2020, requesting at least a six-month adjournment of the trial date in the above-captioned case, which is currently scheduled to commence on April 20, 2020. The Government remains prepared to proceed to trial as scheduled. As is set forth more fully below, while the Government has no objection to a brief adjournment of the trial date subject to the Court’s availability, the requested six-month adjournment is both unnecessary and unwarranted.
By way of background, as is set forth in the Indictment, the charges in this case relate to a period of just over 14 hours—from approximately 4:00 p.m. on August 9, 2019 to approximately 6:30 a.m. the following day, August 10, 2019. The Government has made three discovery productions—(1) the main production on December 31, 2019; (2) a small supplemental production on January 23, 2020; and (3) a reproduction of video surveillance footage with timestamps on January 24, 2020.¹ While the December 31, 2019 discovery production consisted of a large number of pages of materials, many of those materials were produced principally in anticipation of defense requests and to help facilitate the very sort of broader investigation the defendants now claim they need to undertake. For example, the Government produced MCC video surveillance for a period of longer than one month (July 5, 2019 to August 12, 2019); count slips for nearly three weeks (July 23, 2019 to August 14, 2019); thirty-minute round reports for more than a month (July 1, 2019 to August 10, 2019); and materials relating to the events of July 23, 2019. Similarly, with respect to defendant Noel, the Government provided in discovery to her only a report from her cellphone, which consists of more than 20,000 pages, very few of which, if any, are relevant to the pending charges. For substantially the same reasons, and as the Court is aware, the
¹ For the third production, the Government requested additional hard drives from defense counsel. To date, only Noel’s counsel provided a hard drive to the Government, which the Government then loaded and returned to counsel. The Government stands ready to do the same for Thomas as soon as a hard drive is provided.
DOJ-OGR-00021998
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