EFTA00023462

From: ' To: Christian Everdell <CEverdell CohenGressencom>, " , BOBBI C STERNHEIM <[email protected]>, Laura Menninger <[email protected]>, Jeff Pagliuca ipagliuca®hmflaw.com> Cc: Subject: Date: Attachments: RE: Redactions: Government motion in limine Sat, 30 Oct 2021 00:11:41 +0000 2021-10-29_Govit_letter_re_Proposed_Redactions_to_MILs_vl.docx Thanks, Chris. I know you're in the process of filing, but in the meantime, here's a draft joint letter. Thanks, From: Christian Everdell <[email protected]> Sent: Friday, October 29, 2021 7:55 PM To: STERNHEIM <[email protected]>; Laura Menninger <[email protected]>; Jeff Pagliuca <[email protected]> Cc: Subject: (EXTERNAL] RE: Redactions: Government motion in limine All — ; BOBBI C I have confirmed that the government has incorporated all of the defense's proposed redactions within the government's proposed redactions. We do not have any more to add. For the record, we oppose the government redactions that are additional to the defense's redactions. We will now file the defense's motions and exhibits, as redacted/sealed, and then wait for you to file the government's response. It may take a little time to get them all filed, so bear with me. Thanks, Chris From: Sent: Friday, October 29, 2021 6:45 PM To: ; Christian Everdell <[email protected]>• BOBBI C STERNHEIM <[email protected]>• Laura Menninger <Imenninge hmflaw.com>• Jeff Pagliuca <[email protected]> Cc: Subject: RE: Redactions: Government motion in limine All, For filing purposes, attached are redacted versions of the defendant's motions and exhibits, the government's omnibus opposition, and the defendant's omnibus reply. Below are our notes on which exhibits should be sealed. Please let us know if you would like to add any redactions or if you have any questions. EFTA00023462 Defense Motions Sealed The following exhibits should be sealed • Exhibit A to Motion 4 (grand jury testimony) • Exhibit B to Motion 4 (grand jury testimony) • Exhibit 1 to Motion 7 (contact book) • Exhibit 2 to Motion 7 (deposition) • Exhibit A to Motion 8 (inventory) • Exhibit A to Motion 9 (photobook) • Exhibit to Motion 13 (various exhibits) Redactions (attached) • Motion 1 and Exhibit 1 to Motion 1 • Motion 2 and Exhibit A to Motion 2 • Motion 3 and Exhibit 2 to Motion 3 • Motion 4 • Motion 7 • Motion 8 • Motion 9 • Motion 10 • Motion 13 No redactions • We are not seeking redactions to defense opening briefs for defense motions 5, 6, 11, and 12. • We are not seeking redactions to Exhibit 1 to Motion 3 (Government expert notice) Government Opposition • We are not seeking to redact Government exhibits A and B (articles) Defense Reply Sealed The following exhibits should be sealed • Exhibit A (tax documents) • Exhibit B (302) • Exhibit C (medical report) • Exhibit D (transcript) No redactions • We are not seeking redactions to defense Exhibit E (English indictment) From: Sent: Friday, October 29, 2021 6:21 PM To: Christian Everdell <[email protected]>• STERNHEIM <[email protected]>• Laura Menninger <[email protected]>; Jeff Pagliuca <jpagliticaPhmflaw.com> Cc: Subject: RE: Redactions: Government motion in limine ; BOBBI C Happy to jump on a call. We're almost finished with the materials we'll be sending you in a second wave, so why don't we get the first wave filed, and we'll send you the second set, and then we can get on the phone. Does that work? EFTA00023463 From: Christian Everdell <CEverdell@CohenGressercom> Sent: Friday, October 29, 2021 6:19 PM To: • STERNHEIM <[email protected]>• Laura Menninger <Imenningejhmflaw.com>; Jeff Pagliuca <[email protected]> Cc: Subject: [EXTERNAL] RE: Redactions: Government motion in limine BOBBI C Got it. We are filing the response now. I was thinking through the joint cover letter and I think there are a few more logistics we have to discuss. Can you jump on a quick call? From: Sent: Friday, October 29, 2021 6:16 PM To: Christian Everdell <[email protected]>• STERNHEIM <[email protected]>; Laura Menninger <[email protected]>; Jeff Pagliuca <[email protected]> Cc: ; BOBBI C Subject: RE: Redactions: Government motion in limine Thanks for asking - yes, that's correct. From: Christian Everdell <CEverdell@CohenGressercom> Sent: Friday, October 29, 2021 6:06 PM To: BOBBI C STERNHEIM <[email protected]>; Laura Menninger <[email protected]>; Jeff Pagliuca <[email protected]> Cc: Subject: [EXTERNAL] RE: Redactions: Government motion in limine Just so I am clear on sequencing, you are now waiting for us to file the redacted version of our response brief, correct? From: Sent: Friday, October 29, 2021 5:49 PM To: Christian Everdell <[email protected]>; STERNHEIM <[email protected]>• Laura Menninger <[email protected]>• Jeff Pagliuca <[email protected]> Cc: ; BOBBI C Subject: RE: Redactions: Government motion in limine Thanks, Chris. We'll get this first group filed and then send you the next batch. From: Christian Everdell <[email protected]> Sent: Friday, October 29, 2021 5:42 PM To: Menninger <Imenninger hmflaw.com>; Jeff Pagliuca <jpagliucaP hmflaw.com> ; BOBBI C STERNHEIM <[email protected]>; Laura Cc: EFTA00023464 Subject: [EXTERNAL] RE: Redactions: Government motion in limine - The redactions are consistent with what the government had proposed before. We do not have any redactions to add to these documents. But for the record, we object to all of the government's proposed redactions. Please send me the next batch when you have them ready. Thanks, Chris From: Sent: Friday, October 29, 2021 4:55 PM To: Christian Everdell <[email protected]>• BOBBI C STERNHEIM <[email protected]>• Laura Menninger <Imenninger hmflaw.com>; Jeff Pagliuca <jpagliucaPhmflaw.com> Cc: Subject: Redactions: Government motion in limine All, Thanks for the call this afternoon, it was helpful to work through the mechanics of filing redactions this afternoon. As we discussed, we're sending you versions of the following documents, with redactions applied: (1) the Government's motion in limine, (2) the defendant's opposition, and (3) the Government's reply. Please let us know if you would like us to add any redactions to these versions, and we'll get them filed. With respect to Exhibits: • We are attaching a proposed redacted version of Government exhibit A. • Only defense exhibits E and G can be filed publicly without redactions. • All other defense exhibits to the defense opposition should be filed under seal. Best, Assistant United States Attorney United States Attorney's Office Southern District of New York One St. Andrew's Plaza New York, New York 10007 Tel: EFTA00023465