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efta-efta00018893DOJ Data Set 8CorrespondenceEFTA00018893
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From:
To:
Menninger
Cc:
Jeff Pa liuca
Ann
uni.erg
Subject: RE: [EXTERNAL] RE: questionnaires
Date: Sun, 07 Nov 2021 21:49:12 +0000
Attachments: 2021-11-08 joint_letter_regardingjuror_questionnaires.pdf
Attached is a draft of a joint letter. Please let us know if you have any edits — we'll check for accuracy on our end as well,
but we wanted to circulate so that we could all check at the same time. Please note that, for three jurors, we've
withdrawn our objection and joined your position that those jurors should proceed to voir dire. Those juror numbers are:
127, 151, and 458.
Thanks,
Menninger
November 7 2021 3:03 PM
Ann Lundberg
Subject: RE: [EXTERNAL] RE: questionnaires
Sorry Mut
we did not use Excel to prepare our list, so I don't know how to convert it. There may be a way to convert
the pdf to Excel.
From:
Sent: Sunday, November 7, 2021 11:54 AM
To:
Menninger
Cc:
Ann Lundberg
Subject: RE: EXTERNAL RE: questionnaires
eff Pagliucj
With apologies for the delay (we ran into an excel glitch), I'm attaching our current list of proposed strikes. Could you
please send us your list in excel? It makes merging the two lists faster. Thanks!
From:
Menninger
Sent: Sunday, November 7, 2021 1:03 PM
To:
<
>
eff Pagliuca
(I
EFTA00018893
Ann Lundberg
u je :
:
: ques ionnaires
Please find attached Defendant's position on jurors 1-566.
As I understand it, you will be putting ours into the categories described by the Court (joint keeps, joint strikes, gov't only
strikes and defense only strikes) and then re-circulating so that we can both check to ensure ours are entered correctly.
Let me know if you have any questions.
Thanks,
From
Sent: Sunday, November 7, 2021 10:57 AM
To:
Menninger
Cc:
Subject: Re: [EXTERNAL] RE: questionnaires
eff Pagliuca
Thanks very much, sounds good, just let us know when you're ready.
On Nov 7, 2021, at 12:11 PM,
Menninger
Thanks= We are finalizing ours as well and should be done shortly.
From:
Sent: Sunday, November 7, 2021 10:08 AM
To:
Subject: RE: questionnaires
Hi Chris,
Menninger
wrote:
Jeff Pagliuca
That's fine, we've completed our review and our paralegal is compiling a list to send over, which shouldn't take much
longer.
Thanks
From: Christian Everdell
Sent: Sunda November 7 20211:06 AM
To:
Menninger
;Jeff Pagliuca
EFTA00018894
Cc:
Subject: [EXTERNAL] RE: questionnaires
We are still planning to send you our strikes by noon. But we would like to have a simultaneous exchange of strike lists.
Please send us your list at noon as well.
Thanks,
Chris
From: Christian Everdell
Sent: Saturday, November 6, 2021 2:30 PM
To:
elf Pagliuca
Cc:
Subject: RE: questionnaires
That's fine,
M
.
We should be able to get you our strikes by then. Thanks.
From:
Sent: Saturda November 6 2021 12:53 PM
To:
Christian Everdell •
• Jeff Pagliuca
u ect: questionnaires
All,
Menninger
Menninger
Our joint submission is due to the Court tomorrow outlining four categories of juror numbers. We're happy to take on
the task of compiling data for our joint submission. To that end, could you please email us your list of strikes by noon
tomorrow? Once we receive your list, we will compile that data into a letter outlining the four categories of juror
numbers the Court has requested, and we'll send that back to you so that you can double check the accuracy of the
chart. We estimate that process will take a fair amount of time, which is why we'll need your data by noon tomorrow if
you'd like us to coordinate the process.
Thanks,
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00018895
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