roil FOY& SEPLOW I TZE

roil FOY& SEPLOW I TZE a t t o r n e y s a t l aw TEL: 601 WWW.FOYSEPLOWITZ.COM January 29, 2020 AUSA AUSA AUSA US Attorne 's Office - SDNY Re: US v. Tova Noel, et al 19 cr 830 Dear Counsel: I acknowledge receipt of your January 24, 2020 correspondence regarding the surveillance system at the MCC. Based on the information provided in your correspondence and pursuant to Fed. R. Crim. P. 16, please provide the following information and materials: 1. Documents and information related to the initial installation of the video surveillance system at the MCC before and after August 10, 2019, including the entity that was contracted to install it, the date it was installed, and a description of how it operates at MCC; 2. The specific type and model of the video surveillance system before and after August 10, 2019; 3. Rules and regulations regarding the maintenance of the video surveillance systems before and after August 10, 2019; 4. All certifications, maintenance