EFTA00025239

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U.S. Department of Justice United States Attorney Southern District of New York The Silvio!. Mollo Building One Saint Andrew's Plaza New York, New York 10007 December 31, 2019 BY FEDEX Montell Figgins, Esq. Law Offices of Montell Figgins 17 Academy Street, Suite 305 Newark, NJ 07102 Re: United States v. Michael Thomas, No. 19 Cr. 830 Dear Counsel: This letter provides discovery pursuant to Rule 16(a) of the Federal Rules of Criminal Procedure, and seeks reciprocal discovery. This letter and the materials identified herein are subject to the protective order entered in this case on December 16, 2019, and have been designated as "Protected Materials" as defined in the order where noted below. Accordingly, the materials and information identified herein shall not be disclosed to any third party except as set forth in the protective order. I. Disclosure by the Government Based on your request for discovery in this case, and pursuant to the Government's obligations under Rule 16(a), enclosed are copies of the following materials, which are being produced to all defendants and are stamped with the following control numbers:' Description Bates Numbers Classification Pursuant to Protective Order MCC surveillance footage from 7/5/2019 to 8/12/20192 SDNY_00000001 Protected Materials In addition to information provided herein, please note that this Office periodically posts content on social media platforms including Twitter, Facebook and YouTube. Membe