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10 et, i 138 14 15 16 ey 18 a 20 21 aD. 23 24 25 Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 4 of 30 App.-0807 G4LMGIUC in Utah. He will be able to handle the Colorado depositions and things of that nature. We are here because those pro hac vice motions are being contested. The core piece of that is the argument that they should not be allowed to seek confidential information in this case. Your Honor will remember that I was before you a couple of weeks ago again trying to get the deposition of the defendant, which is set for tomorrow, but still hasn't occurred yet. And in order to expedite that process I agreed to the protective order that was put in front of the Court and I waived all of my objections to that in order to be able to facilitate and move that deposition forward. That protective order provides that attorneys who are actively working on the case can receive confidential material. My opposing counsel has interpreted that to mean that that must be a counsel of record in the case. We disagree with that interpretation. JI wouldn't have agreed to a protective order knowing that they were already working on the case. If that were the situation, as your Honor can understand in this case, the majority of the material has been marked confidential, so it would prohibit my cocounsel from working on behalf of their client. Your Honor, I'm here to request on behalf of my client, Virginia Giuffre, that she be entitled to have her counsel of record of choice in this matter. If your Honor will SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0500 DOJ-OGR-00003806