Subject: RE: draft letter re: unsealing

From: To: Subject: RE: draft letter re: unsealing Date: Thu, 20 Aug 2020 19:45:03 +0000 Attachments: Exhibit_A _to_2020.08.21_Govemment_letter_re_proposed_redactions_and_sealing.pdf; 2020-08- 21,_GMJetter to_Judge_Nathan_re_proposed_redactions_&_sealing_of defense_motion.d ocx Attached is a proposed letter to Judge Nathan regarding redactions/sealing. The portions highlighted in red are the portions I propose to redact when filing the letter on ECF. Please let me know if any of you guys have any edits, or would rather propose a different approach. before I send to the chiefs. From: Sent: Thursday, August 20, 2020 12:03 PM To: (USANYS) >; Subject: RE: draft letter re: unsealing Proposed redactions attached. In addition to these, I think we can propose that-affidavit be filed publicly without redactions and that all of the exhibits be filed under seal. From: Sent: Thursday, August 20, 2020 11:49 AM To: ) <->; (USANYS) Subject: RE: draft letter re: unsealing Thanks so much for putting this together. Some proposed edits in track. And I insist that your name be on this—even if it's the last thing you'll write in this case, you should have your name on your excellent work product. I'll circulate proposed redactions to letter motion in a bit. From: Sent: Thursday, August 20, 2020 1:56 AM To: (USANYS) Subject: draft letter re: unsealing cna Team — I hope this wasn't a disastrous instinct, but as I got into writing this tonight, it seemed more and more to me like I could do it without having to put anything under seal. See what you think?? I just don't know that it's necessary to get into every little accusation and innuendo; I feel like it should be straightforward — they're trying to get around the protective order that was entered less than a month ago, and there's no good cause. In particular, I don't know that it would be productive to get into a fight about whether or not the materials are likely to affect the civil cases, because realistically Judge Nathan likely won't be well positioned to evaluate those intricacies. And I EFTA00087952 think it's doable at a level of abstraction that highlights just how uncontroversial it is to get a subpoena (and ask a court to bless it). All that said, of course let me know what you think — I can always rework tomorrow afternoon if necessary, and in particular if anybody thinks it's insufficient. And/or feel free to just make changes in it and take it from there—I have no pride of authorship and obviously one of you guys will ultimately sign. So whatever is preferable for y'all. many thanks, EFTA00087953