SCHILLER

BSF BOIES SCHILLER FLEXNER VIA ELECTRONIC MAIL United States Attorney's Office for the Southern District of New York Dear PETER M. SKINNER April 18, 2019 FOIA CONFIDENTIAL TREATMENT REQUESTED / FED. R. CRIM. P. 6(e) MATERIAL Re: Grand Jury Subpoena Investigation I write on behalf of Boies Schiller Flexner LLP ("BSF") with regard to a grand jury subpoena, dated February 5, 2019, that you directed to this firm (the "Subpoena"). I am also in receipt of the Sealed Order, 19 Misc. 149, signed by Judge McMahon and dated April 9, 2019. Pursuant to that Order, we are producing the following materials in e to the Subpoena that are covered by the March 18, 2016 Protective Order entered in v. Maxwell, 15 Civ. 7433 (RWS): All deposition transcripts All expert deposition transcripts Plaintiff's Productions Defendant's Productions Non-Party Productions All related deposition exhibits All related expert deposition transcripts D00001 -1.305485 GM_00015 - GM_0 CASSELL 000001 - CASSELL 014402 MAR-A-LAGO 0001 - MAR-A-LAGO 0607 000001 - 000558 RO(UK)_000001 - RO(UK)_000009 VICTIMS_REFUSE_SILENCE_0001-0091 The documents can be accessed through our secure BSF sharefile site which we will send a link to separately with instructions to access the documents. Additional materials will be provided on a rolling basis. BOIES SCHILLER FLEXNER LLP New York. NY 10O01 I ( wwwbsthp.com EFTA00080981 BSF United States Attorney's Office for the Southern District of New York Page 2 BSF respectfully requests that this letter and the enclosed production be treated as confidential. These materials have been designated "FOIA Confidential Treatment Requested / Fed. R. Crim. P. 6(e) material," and are provided pursuant to and in reliance on the confidentiality provisions of Rule 6(e) of the Federal Rules of Criminal Procedure. BSF further respectfully requests that this letter and the enclosed production be treated as confidential under the Freedom of Information Act ("FOIA"), including pursuant to 5 U.S.C. §§ 552(b)(3), (b)(4), (b)(6), and (b)(7), as well as the FOIA regulation, 28 C.F.R. § 16.8. BSF further respectfully requests confidential treatment of this letter and the enclosed production under the Privacy Act of 1974, 5 U.S.C. § 552a, as well as the provisions of 18 U.S.C. § 1905. By submitting these materials, BSF does not intend to and does not waive the protections of the attorney-client privilege, the attorney work product doctrine, or any other applicable privilege or protection. In the event that the Government receives a FOIA request for any documents provided by BSF, we ask that you please immediately notify us at the numbers above. Likewise, if the Government, for whatever reason, determines to release the materials, we ask that you notify us so that BSF can substantiate its request for confidential treatment, object, or pursue any other available remedies. Finally, should the Office determine to share BSF's production with any other federal agency, please forward a copy of this letter, as well, and indicate that BSF has requested confidential treatment of materials. If you have any questions about BSF's production, or would like to speak further, please feel free to call us at the numbers above. Very truly yours, /s Peter M. Skinner Peter M. Skinner EFTA00080982