FOY& SEPLOW I TZE

FOY& SEPLOW I TZE a t t o r n e y s a t l aw HACKENSACK. NJ 07601 TEL: FAX: AUSA AUSA AUSA US Attorney's Office - SDNY New York, NY 10007 NEW YORK. NY 10005 WWW.FOYSEPLOWITZCOM TEL June 5, 2020 Re: US v. Tova Noel, et al 19 cr. 830 Dear Counsel: Pursuant to Fed. R. Crim. P. 16, please provide the following information and materials: 1. Defendant Noel's complete personnel and training file including, but not limited to, the following: a. Individual employee training record. b. Complete Performance Log maintained in the Admin Lieutenant's Office or any other location in the MCC. c. Completed and signed Position Description Cover Sheet. d. Completed and signed yearly Employee Performance Appraisal. e. Completed and signed quarterly performance logs completed at the end of the 3", 6th, and 9th month of Defendant Noel's employment. f. Completed and signed 6th month progress review. g. BOP GLYNCO (FLETC) training information and course outline for 2019. 2. Th