DOJ-OGR-00022063

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Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page1 of 34 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA 2 19 Cr. 830 (AT) TOVA NOEL and MICHAEL THOMAS, Defendants. MEMORANDUM OF LAW OF THE UNITED STATES OF AMERICA IN OPPOSITION TO DEFENDANT MICHAEL THOMAS’S MOTION TO COMPEL GEOFFREY S. BERMAN United States Attorney Southern District of New York Rebekah Donaleski Jessica Lonergan Nicolas Roos Assistant United States Attorneys - Of Counsel - DOJ-OGR-00022063

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