From: ' y, To: ' Subject: bumping! Date: Tue, 11 Aug 2020 17:24:59 +0000 Attachments: letter_to_USA_re_protective_order (002)_(002)final.pdf Inline-Images: image00 1 jpg Thanks very much. Also, I know we disagree on this (a non-passive-aggressive instance of "reasonable minds can disagree"l), so just in the interest of transparency I think there's case law that strongly suggests we need to disclose the victim names. I'll send that around, but obviously if you have anything else on the subject, don't hesitate to send, and all without prejudice to further discussion. Thanks as always. From: Sent: Monday, August 10, 2020 11:37 To: ) "t Cc: Subject: FW: Letter regarding discovery attached. I think is particularly swamped this week —can you please take the lead on whatever we're going to do with this (i.e., presumably whatever the chiefs decide)? My personal vote would be to tell them that the protective order explicitly precludes the use of criminal grand jury materials in Maxwell's civil cases, and the materials are sealed because they relate to an ongoing grand jury investigation and they should feel free to raise the issue with Nathan and we'll respond. (And I would think our response could basically be a copy-paste of the letter I wrote to Netburn.) We could also note in our response to Jeff and Laura, if we wanted to, that given their awareness of the materials, we assume they will retract the obviously false claims about government malfeasance. All that said, I also wouldn't object if they just want to allow them to file these materials under seal; I don't think it matters hugely. If we could have resolved (et al) by now, none of this would be an issue. thanks, From: Jeff Pagliuca <[email protected]> Sent: Sunday, August 09, 2020 18:56 To: ; -)°>; ) Cc: Laura Menninger <[email protected]>: Christian Everdell <CEverdell@CohenGressercom>, Mark S. Cohen <mcoheneCohenGressercom>, Nicole Simmons <[email protected]> Subject: Letter regarding discovery attached. Dear Counsel, Please see attached conferral letter. Jeff EFTA00021875

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