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Case 1:20-cr-00330-PAE Document528 Filed 12/06/21 Page8sof8 the context in which it was made. Indeed, that statement is one of several in the notes, and to avoid misleading the jury, Glassman would also have to describe and provide context to the remaining points reflected in the note. Doing all this would require Glassman to go well beyond the notes, exceeding the scope of any privilege waiver. Ii. Conclusion For the foregoing reasons, the Court should preclude testimony by Jane’s counsel. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: ___s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Souther District of New York Cc: Defense Counsel (by ECF) DOJ-OGR-00008244