To: Robert Glassman <
From: `z IMIE> To: Robert Glassman < Cc: , Nathan Werksman Subject: RE: SDNY investigation Date: Mon, 30 Dec 2019 21:09:37 +0000 I II Robert, Following up on our most recent meeting with you and we wanted to confirm that it's alright for us to begin reachin out this week to the contacts she identified for us -- in articular, we would initially expect to contact , and and then Howie Simon, Dr. Cabe, and John Larkin. We also wanted to see if it we are able at this stage to contact her mother, who is potentially a key witness -- I know had wanted to speak with her mother in advance of us doing that. Please let us know if it's alright to make those calls? And separately, if you could please let us know if her brother has happened to have any contact with since we last spoke -- no problem at all if not, but I think she mentioned that was a possibility so wanted to check. Thanks very much, and hope you're having a good holiday season. thanks again, Ori inal Messa e
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From: `z IMIE> To: Robert Glassman < Cc: , Nathan Werksman Subject: RE: SDNY investigation Date: Mon, 30 Dec 2019 21:09:37 +0000 I II Robert, Following up on our most recent meeting with you and we wanted to confirm that it's alright for us to begin reachin out this week to the contacts she identified for us -- in articular, we would initially expect to contact , and and then Howie Simon, Dr. Cabe, and John Larkin. We also wanted to see if it we are able at this stage to contact her mother, who is potentially a key witness -- I know had wanted to speak with her mother in advance of us doing that. Please let us know if it's alright to make those calls? And separately, if you could please let us know if her brother has happened to have any contact with since we last spoke -- no problem at all if not, but I think she mentioned that was a possibility so wanted to check. Thanks very much, and hope you're having a good holiday season. thanks again, Ori inal Messa e
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From: Kevin Boyle
From: Kevin Boyle To: Robert Glassman Cc: Nathan Werksman Subject: Re: SDNY investigation Date: Wed, 12 Feb 2020 16:58:56 +0000 Also all— No objection that I can see from ud regarding these subpoenas (without having see. them), but note that some states (CA at least, in civil cases) a "Notice to Consumer" must be done with subpoenas like this. If it is not done, then the entity can not produce anything demanded in the subpoena. I'm not sure if the same requirement applies to criminal subpoenas. Kevin R. Boyle www.psblaw.com > On Feb 12, 2020, at 8:55 AM, Robert Glassman < wrote: > Thanks for letting us know. Can you send me a list of the schools you've subpoenaed and reached out to? Just want to make sure if she gets a call from someone, it is actually from someone who you've contacted and is legit. As you can imagine, there are lots of calls and emails to her and her manager saying all kinds of stuff. > Robert Glassman, Esq. > Panish Shea & Boyle LLP > Web: www.psbl
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From: '1
From: '1 ~ 1. ~la To: Robert Glassman Cc: , Nathan Werksman Subject: RE: SDNY investigation Date: Wed, 12 Feb 2020 17:30:59 +0000 Kevin Boyle Of course, and I should say, if it's alright, we can give the schools our information in the first instance in the hopes that they're willing to go through you rather than bothering irectly (or if that adds complications, rather than reducing them, let us know). The schools / entities are n 'ew 'or .In p u , mu r m•yr n n pr r- .r ac, T. y connect with you separately on a , and we can continue to keep you posted. As to Kevin's note, ordinarily there's no notice requirement, but there are some unusual rules that apply to educational institutions, which we think is driving some of the back-and-forth we're having. Thanks for your help with this, as always, and we'll keep in touch on this. Original Message From: Robert Glassman ‹ > Sent: Wednesda Febru• 12, 2020 11:55 To: Cc: Nathan Werksman '-; Kevin Boyle Subject:
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