EFTA00021875

From: ' y, To: ' Subject: bumping! Date: Tue, 11 Aug 2020 17:24:59 +0000 Attachments: letter_to_USA_re_protective_order (002)_(002)final.pdf Inline-Images: image00 1 jpg Thanks very much. Also, I know we disagree on this (a non-passive-aggressive instance of "reasonable minds can disagree"l), so just in the interest of transparency I think there's case law that strongly suggests we need to disclose the victim names. I'll send that around, but obviously if you have anything else on the subject, don't hesitate to send, and all without prejudice to further discussion. Thanks as always. From: Sent: Monday, August 10, 2020 11:37 To: ) "t Cc: Subject: FW: Letter regarding discovery attached. I think is particularly swamped this week —can you please take the lead on whatever we're going to do with this (i.e., presumably whatever the chiefs decide)? My personal vote would be to tell them that the protective order explicitly precludes the use of criminal grand jury materials in Maxwell's civil cases, and the materials are sealed because they relate to an ongoing grand jury investigation and they should feel free to raise the issue with Nathan and we'll respond. (And I would think our response could basically be a copy-paste of the letter I wrote to Netburn.) We could also note in our response to Jeff and Laura, if we wanted to, that given their awareness of the materials, we assume they will retract the obviously false claims about government malfeasance. All that said, I also wouldn't object if they just want to allow them to file these materials under seal; I don't think it matters hugely. If we could have resolved (et al) by now, none of this would be an issue. thanks, From: Jeff Pagliuca <jpagliuca@hmflaw.com> Sent: Sunday, August 09, 2020 18:56 To: ; -)°>; ) Cc: Laura Menninger <ImenningejL@hmflaw.com>: Christian Everdell <CEverdell@CohenGressercom>, Mark S. Cohen <mcoheneCohenGressercom>, Nicole Simmons <nsimmons@hmflaw.com> Subject: Letter regarding discovery attached. Dear Counsel, Please see attached conferral letter. Jeff EFTA00021875 Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 Main 303.831.7364 FX 303.832.2628 JpagliucaPhmflaw.com www.hmflaw.com mation that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you EFTA00021876