EFTA00013434

From: To: Subject: FW: Date: Thu, 29 Apr 2021 19:01:06 +0000 Attachments: 2021-04-30 _ Gov't_ Letter to Manley.v3.docx Updated version attached. Let me know if you're good with this, and I'll send a pdf to defense counsel. FYI I've changed the cc line, since BSF is now in theory counsel of record in the case, and we're not sending this to them. From: (USANYS) Sent: Thursday, April 29, 2021 2:45 PM To: Cc: Subject: RE: nice work on this, my edits are attached. From: Sent: Thursday, April 29, 2021 11:01 AM To: (USANYS) Cc: Subject: RE: ) < >; >; (USANYS) (USANYS) < (USANYS) (USANYS) In case it's useful while we're troubleshooting this issue today, I'm attaching the working draft. We'll let you know if we find additional authorities on this or obtain different guidance From: Sent: Thursday, April 29, 2021 10:32 AM To: (USANYS) (USANYS) Cc: Subject: >; >; (USANYS) < >; (USANYS) S; We're working on drafting a letter in response to the attached, and wanted to give you a heads up. We hope to have a draft for you this afternoon, in the hopes of sending the draft to defense counsel tonight as part of the meet-and-confer directed by Judge Nathan. I think that leaves sufficient time for filing tomorrow. Although we're mindful of third party privacy interests, for non-parties who are neither witnesses nor victims in the case, I do have concerns about entertaining redaction/intervention requests, given the high volume of people who may ask to be heard or assert a right to review and redact documents if this were entertained. Thanks, EFTA00013434 Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 EFTA00013435