From: ' r H To: a Subject: RE: Letter regarding discovery attached. Date: Wed, 12 Aug 2020 15:59:18 +0000 Attachments: 2020-08-12,_GMJetter to_defense_counsel_re_discovery.docx Inline-Images: image001.jpg Draft letter response attached. Let me know if you have any revisions before I send to the chiefs. From: Sent: Monday, August 10, 2020 2:02 PM To: Subject: RE: Letter regarding discovery attached. Thanks for sending, M . I agree with this approach, though defer to if she's handling, and thanks in advance. On the last point: I do think we have a firm view that they should not be filing our discovery materials in civil cases. I don't care about the substance of these particular documents, but I think we agree that is an important aspect of the protective order to assert, both in this instance and in general, so this issue doesn't continue to crop up. From: Sent: Monday, August 10, 2020 11:37 AM To: ) Cc: I `: => 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 <ImenningDVhmflaw.com>. Christian Everdell <[email protected]>; Mark S. Cohen <[email protected]>; Nicole Simmons <[email protected]> Subject: Letter regarding discovery attached. EFTA00030902

Dear Counsel, Please see attached conferral letter. Jeff Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 Main 303.831.7364 FX 303.832.2628 JpaglIucagThmflaw.com www.hmflaw.com mation 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 EFTA00030903