EFTA00021918

From: ' cti To: Christian Everdell " II Cc: "Mark S. Cohen" , Jeff Pagliuca ci 'Laura Menninger' Subject: RE: Protective Order Date: Sat, 25 Jul 2020 20:13:13 +0000 Attachments: 2020-07-25,_GM,_protective_order,_clean_version.docx Inline-Images: image001.png; image002jpg Chris, Following up on our discussion last night, attached please find a revised draft protective order. As we discussed, although this does not represent a version that has been formally approved internally at our Office, it is an effort to include the updates and edits we talked through yesterday. I believe this should represent what we addressed, but I also realize that we've revised some aspects that you mentioned you'd need to further consider, and there is some new proposed language in areas you suggested we clarify, so I expect it may be useful to chat again once you've reviewed. All that said, we wanted to get you the revised version quickly, and I'm happy to discuss again, including anytime this weekend if that's helpful, to go through any outstanding issues. thanks, From: Christian Everdell Sent: Wednesday, July 22, 2020 20:13 To: •c > C Cc: Mark S. Cohen ,: ); Jeff Pagliuca < 'Laura Menninger' Subject: Protective Order Attached is a revised draft of the defense's proposed Protective Order (including a redline against the government's original draft and a clean version). We did our best to incorporate the points we discussed on our last call on Monday, July 20 and to find points of common ground and agreement. Please let us know by 5pm tomorrow whether the attached draft is acceptable to the Government. Regards, Chris Christian Everdell COHEN & GRESSER LLP 800 Third Avenue New York. NY 10022 EFTA00021918 www.cohengresser.com view bio New York I Seoul I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error, please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. PRIVACY: A complete copy of our privacy policy can be viewed a! Mos:/Awow.cohengressercom/privacK-policx EFTA00021919