From: To: Laura Mennin. er • Jeff Pagliuca Cc: '1 >, aff,IJSANrai > ) 4° Subject: RE: [EXTERNAL] Proposed Jury Questionnaires Date: Wed, 13 Oct 2021 01:35:59 +0000 Attachments: 2021.10.12 Joint_proposed_Maxwell_Trial_Length_Letters _v3.pdf Thanks, Laura. This works for us — we've just added a couple sentences noting our production yesterday to our section. I'll plan to file this at 10. Shanks From: Laura Menninger Sent: Tuesday, October 12, 2021 7:58 PM To: Pagliuca ‹ > Cc: ) (USANYS) Subject: RE: [EXTERNAL] Proposed Jury Questionnaires < >.H > ; Jeff Thanks. Here is our position for the joint letter. I'll leave to your discretion whether you want to keep the final paragraph of your position given it is redundant of the joint position. Also, I'm not clear why our report to you would be spelled out in your position rather than ours, so I moved it. Thanks — Laura From: Sent: Tuesday, October 12, 2021 5:46 PM To: Laura Menninger Cc: (USANYS) •t > Subject: RE: [EXTERNAL] Proposed Jury Questionnaires Hi Laura, That works for us. Attached is a revised letter with our position and space for the defense position. Thanks, Jeff Pagliuca From: Laura Menninger Sent: Tuesday, October 12, 2021 7:09 PM EFTA00067105
To: I < : I ; Jeff Pagliuca < > Cc: c >; >: (USANYS) Subject: RE: [EXTERNAL] Proposed Jury Questionnaires Hi I do think the Court should understand why we cannot provide a better estimate, in part because our client has been unable to view the exhibit and witness lists. If you want to break up the letter into Government's position and Defendant's position, we could do that. I think the Court will not be pleased with two different letters on the same topic. Thanks, Laura From: Sent: Tuesday, October 12, 2021 4:52 PM To: Laura Menninger Jeff Pagliuca < Cc: (USANYS) ;I S Subject: RE: [EXTERNAL) Proposed Jury Questionnaires Hi Laura, We don't understand the additions to this letter, which appear to be about the mechanics of yesterday's production. If you would like to file a separate letter about that, you're of course free to do so, but the Court has ordered us to provide a joint letter estimating the trial length. To the extent you'd like us to let the Court know that you are not able to provide an estimate until closer to trial or until you've had more opportunity to review the materials produced yesterday, we can include language along those lines. But we're not able to agree to a joint letter with language complaining about the drive delivery, which is not responsive to the Court's order. Please let us know whether you would agree to language along those lines or whether we should file separate letters. Thanks, From: Laura Menninger Sent: Tuesday, October 12, 2021 5:46 PM To: Pagliuca < => Cc: CM. >; (USANYS) ‹ > Subject: RE: [EXTERNAL] Proposed Jury Questionnaires ;1 >; ;Jeff We have not yet received it but will take you at your word that it should be delivered today. I've edited our portion of the letter accordingly. Thanks, EFTA00067106