EFTA00021898

From: ' < To: Jeff Pagliuca ipagliuca®hmflaw.com> Cc: , Nicole Simmons <nsimmons®lunflaw.com>, ' "CEverdell®CohenGressencom" <CEverdell@cohengressencom>, "mcohen@CohenGressencom" <mcohen®cohengressencotn>, Laura Menninger <[email protected]> Subject: RE: Letter regarding discovery attached. Date: Wed, 12 Aug 2020 20:51:58 +0000 Attachments: 2020-08-12 _letter to_GM_counsel_re_discovery.pdf Jeff, Attached please find the Government's response to your August 9, 2020 letter. Best, Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 From: Jeff Pagliuca ipagliuca@hmflawcom> Sent: Tuesday, August 11, 202011:45 PM To: ) `c .> Cc: I •td >; Nicole Simmons <[email protected]>; < >; [email protected]; [email protected]; Laura Menninger <[email protected]> Subject: Re: Letter regarding discovery attached. I'm not sure I can wait for a decision until Thursday. I will discuss with my colleagues and attempt to confer with the Government by phone tomorrow. Absent any additional information from the government you are not leaving me with any realistic options and I will probably need to simply advise Judge Nathan that the government's position is forthcoming but because we learned about the information on Friday and the Circuit's tight schedule we could not wait any longer. A phone call tomorrow would be appreciated. Jeff EFTA00021898 On Aug 11, 2020, at 9:07 PM, Jeff, wrote: We are still considering your request, and we will reach out when we are prepared to provide you with our response, which will be no later than Thursday, August 13th. Best, From: Jeff Pagliuca <[email protected]> Sent: Tuesday, August 11, 2020 7:28 PM To: Cc: >; Nicole Simmons <[email protected]>• >; CEverdell@CohenGressercom• [email protected]• Laura Menninger <[email protected]> Subject: Re: Letter regarding discovery attached. Looks like our email is back up. As indicated in the gmail email I would like to discuss your position by phone tomorrow. I am available any time. Jeff On Aug 11, 2020, at 12:19 PM, wrote: Good afternoon, We will provide you with our response by this Thursday, August 13th. We will, of course, send the response sooner if we are able. Best, Assistant United States Attorney Southern District of New York l St. Andrew's Plaza New York, NY 10007 From: Sent: Monday, August 10, 2020 5:28 PM To: Nicole Simmons <[email protected]>• I sc ›; ) >• CEverdell@CohenGressercom• [email protected] EFTA00021899 Cc: Laura Menninger <[email protected]>• Jeff Pagliuca <[email protected]> Subject: RE: Letter regarding discovery attached. Good afternoon, We are in receipt of the email and letter. We will respond as soon as we are able. Regards, Alex. Assistant U.S. Attorney Southern District of New York 212.637.2415 From: Nicole Simmons <[email protected]> Sent: Monday, August 10, 2020 16:18 To: 4: >; [email protected]• mcohen@CohenGressencom Cc: Laura Menninger <[email protected]>• Jeff Pagliuca <[email protected]> Subject: FW: Letter regarding discovery attached. Dear Counsel, >; At the request of Jeffrey Pagliuca please see the attached letter. Our firm is currently experiencing technical issues with our email system. If you would please kindly confirm receipt of this email and the attachment it would be greatly appreciated. Thank you, Nicole From: Jeff Pagliuca <[email protected]> Sent: Sunday, August 09, 2020 4:56 PM To: Cc: Laura Menninger <[email protected]>• Christian Everdell <[email protected]>• Mark S. Cohen <[email protected]>• Nicole Simmons <[email protected]> Subject: Letter regarding discovery attached. Dear Counsel, Please see attached conferral letter. Jeff <image00 I jpg> Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 Main 303.831.7364 FX 303.832.2628 [email protected] www.hrtiflaw.Com EFTA00021900 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 EFTA00021901