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This document is a formal discovery request dated January 29, 2020, from Montell Figgins (attorney for Michael Thomas) to AUSA Rebekah Donaleski regarding the case 'United States v. Michael Thomas' (incorrectly listed as State of NY in the Re: line, but with federal docket 1:19-cr-00830). The letter requests all materials (reports, photos, videos) possessed by the United States Inspector General pursuant to Rule 16(a)(1)(C). It cites U.S. v. Bryan as legal precedent for the entitlement to these documents.