EFTA00023756

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U.S. Department of Justice United States Attorney Southern District of New York The Silvio!. Mdlo Building July 20, 2020 BY EMAIL Jason E. Foy Fo & Se lowitz LLC Re: United States v. Tom Noel, No. 19 Cr. 830 Dear Mr. Foy: We write in response to your discovery request letter, dated June 5, 2020. Many of the items requested in your letter were previously produced to the defendant in discovery, and to the extent they were not, that is because they were not in the Government's possession. While, as the Court has already ruled, the Government has no obligation to gather additional documents from the Bureau of Prisons ("BOP") in response to a discovery request, and you identify no authority to the contrary in your request, as a courtesy, the Government made a supplemental request to the BOP for certain records responsive to your requests and that appear to have at least some relevance to the issues related to this case. Pursuant to that supplemental request, the BOP began producing records to our Office on or around June 24, 2020, and we are now producing those materials to you. This letter and the content herein is designated as "Protected Materials" pursuant to the Protective Order entered in this matter. By contrast, as set forth herein, the Government has not requested materials not already in its possession that do not seem to have any relevance to this case, although we are happy to discuss the basis for any such request at your convenience. Requ