EFTA00032783

From: ' To: '1 (USANYS (USANYS)" Cc: =Mir Subject: RE: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial] Date: Thu, 22 Apr 2021 20:09:31 +0000 Attachments: 2021-04-22 Gov't letter re GM request_for_adjoumment v4.docx: 2021-04- 22=Ilietter re -_request_to_file_un—der_seal.docx Thanks very much, Attached please find a revised draft incorporating your edits. I've also attached a draft sealed letter informing AJN of From: (USANYS) Sent: Thursday, April 22, 2021 3:06 PM To: ) (USANYS) Cc: (USANYS) Subject: RE: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial] Thanks this is well done, and my edits are attached. As you'll see, I suggested >; Happy to look at another version before filing, thanks very much. From: Sent: Thursday, April 22, 2021 1:32 PM To: (USANYS) Cc: (USANYS) Subject: RE: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial] Draft response attached. From: Sent: Thursday, April 22, 2021 12:14 PM To: (USANYS) (USANYS) Cc: Subject: FW: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial] (USANYS) cc > (USANYS) FYI. Our response is due at 5 today. From: Laura Menninger Sent: Thursday, April 22, 2021 11:22 AM To: Cc: 14t ); (USANYS) >; < >; Jeff Pagliuca ca; 'Bobbi Sternheim EFTA00032783 Y >; Nicole Simmons Subject: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial] Judge Nathan - Pursuant to this Court's Order of April 20, 2021 (Dkt. 221), attached please find counsel's Letter Motion for an Adjournment of the trial. Counsel for Ms. Maxwell request redaction of their other clients' names and case numbers from this Letter Motion pursuant to Rule of Professional Conduct 1.6 which prohibits lawyers from revealing confidential information related to a client even where that information is publicly available. See In Re. Anonymous, 654 N.E. 2.d. 1128 (Ind. 1995) (lawyer violated Rule 1.6 by disclosing information relating to representation of client, even though information "was readily available from public sources and not confidential in nature"); In re Bryan, 61 P.3d 641 (Kan. 2003) (lawyer violated Rule 1.6 by disclosing, in court documents, existence of defamation suit against former client); State ex reL Okla. Bar Ass'n v. McGee, 48 P.3d 787, 791 (Okla. 2002) (a lawyer's duty of confidentiality attaches "to all information relating to the representation, whatever its source"). Upon direction of the Court, counsel will file either the redacted or unredacted version of this letter on the public docket. Best regards, Laura Menninger Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. EFTA00032784