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From: " y, To: " y, Cc: ' " < >, ' (USANYS)" Subject: Re: Conferral Regarding Possible Violation of Local Criminal Rule 23.1 Date: Fri, 07 May 2021 21:58:39 +0000 Ok, MI can you start the tree in a bit when you're ready? On May 7, 2021, at 5:53 PM, Agree. I'm free this evening and tomorrow. From: Sent: Friday, May 7, 2021 5:32 PM To: 1< M> Cc: (USANYS) Subject: Re: Conferral Regarding Possible Violation of Local Criminal Rule 23.1 ) < wrote: Makes sense to me. I'm free starting at 6:15 or 6:30, or pretty much anytime tomorrow. On May 7, 2021, at 5:25 PM, <-> wrote: The short answer is no, he does not, but let's discuss next time we talk. I'm around probably until 7 this evening if the team wants to talk about pending issues before then. I think we need to discuss: 1) this email, 2) the MDC letter, and 3) the letter due Monday. I think we should also schedule a time to talk on Monday about the motions they're filing tonight. Friday, May 7, 20211.0 From: Laura Menninger < Sent: To: I Cc: Jeff Pagliuca Sternheim Subject: Conferral Regarding Possible Violation of Local Criminal Rule 23.1 Counsel — (USANYS) ; 'Bobbi The linked article by the Sun dated yesterday contains a number of statements which, if made by a lawyer associated with a witness in this case, appear to violate Local Criminal Rule 23.1. See also Dkt. No. 28 (expectation of strict compliance with Rule 23.1 by "counsel for all involved parties"). The rule applies by its terms to any "lawyer participating in or associated with the investigation (including ... lawyers for targets, subjects, and witnesses in the investigation...)." https://www.thesun.co.uk/news/14875477/ghislaine-maxwell-plea-deal-same-fate-as-epstein/ EFTA00090017 I am writing to confer with you prior to bringing this to the Court's attention. Please let me know if you believe Mr. Spencer Kuvin represents any witness in this case. Given the urgency of this situation, I would appreciate a response by close of business Monday. Thanks, Laura <image001.jpg> Laura A. Menninger Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 www.hmflaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain information that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you. EFTA00090018