EFTA00068410.pdf

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: ceverdel Subject: (EXTERNAL] Re: Subpoena fod ; Laura Menninger EFTA00068410 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. 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 this subpoena? We haven't seen a copy. Thank you. Brian T. Burns Smith Villazor LLP From: Christian Everdell Sent: Tuesday, November 16, 2021 8:48 PM To: Patrick Smith Cc: Jeff Pagliuca >; ; Brian Burns Laura Menninge (USANYS) Subject: [EXTERNAL EMAIL] Subpoena for■ Counsel — Attached please find the signed subpoena foi Regards, Christian R Everdell COHEN & GRESSER LLP 800 Third Avenue New York. NY 10022 www.cohengresser.com New York I Paris I view bio I Washington DC I London Please acknowledge receipt. BOBBI C STERNHEIM 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. II 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. EFTA00068411 PRIVACY: A complete copy of our privacy policy can be ✓owed al httpsActaw.cohengresser.com/privacK-policy EFTA00068412