From: Brian Bums
Summary
From: Brian Bums To: Cc: "ceverdel "bestemlielin (USANYS)" Subject: [EXTERNAL] RE: Subpoena fo Date: Sat, 20 Nov 2021 19:44:11 +0000 Attachments: 2021.11.15_-_ 1 - Letter from Patrick J. Smith to Judge_Nathan.pdf Jeff Pagliuca Inline-Images: image001.gif; image002.jpg Counsel - We are required to file our Nov. 15 letter to Judge Nathan on the public docket by tomorrow (copy attached for reference). We do not intend to apply any redactions. I assume that neither the government nor the defense proposes any redactions to this letter, but I'd appreciate confirmation before we file. Thanks, Brian T. Burns Smith Villazor LLP From: Sent: Wednesday, To: Jeff Pagliuca November 17, 2021 9:27 PM Brian Burns (USANYS) Subject: (EXTERNAL EMAIL] RE: Subpoena for Jordana Feldman >; Laura Menninger Thanks, Jeff. Brian, in light of Jeff's email, attached is the unredacted defense motion. Thanks. From: Jeff Pagliuca Sent: Wednesda November 17 2021 9:07 PM To: Brian Burns Cc:
Persons Referenced (4)
“...Accordingly, we will defer to it as to what you should receive. Best Regards, Jeffrey S. Pagliuca. On Nov 17, 2021, at 7:58 PM, Brian Burns wrote: Defense counsel — Would you...”
Defense Counsel“...gards, Jeffrey S. Pagliuca. On Nov 17, 2021, at 7:58 PM, Brian Burns wrote: Defense counsel — Would you please provide us a copy of your motion seeking the issuance of thi...”
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From: '• To: Jeff Pagliuca Cc: "ceverdel C (USANYS)" Subject: RE: Subpoena for Date: Thu, 18 Nov 2021 02:27:03 +0000 Attachments: 2021.11.14 Mm forOrderAuthaSubPursm_to_F.R.Crim.P_17(c) 2021.11.14_Ex._1.pdf Inline-Images: image001.gif; image002.jpg Thanks, Jeff. Brian, in light of Jeff's email, attached is the unredacted defense motion. i ns hanks From: Jeff Pagliuca Sent: Wednesday, November 17, 2021 9:07 PM To: Brian Burns Cc: ceverdel Subject: [EXTERNAL] Re: Subpoena for >; Laura Menninger Brian, I believe that we were waiting for any proposed redactions from the government. We have no problem with the government sending you a copy of the motion. If the government does not object, we will send it. However, the government has designated every production confidential, subject to its protective order, and the motion contains information designated as confidential. Accordingly, we will defer to it as to what you should receive. Best Regards, Jeffrey S. Pagliuca.
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