From: ' (USAFLS)" czi To: (USAFL$)" ctl - - Subject: RE: Voluntary Production of Materials?l Date: Wed, 11 Jan 2012 18:17:00 +0000 Importance: Normal I will be at courthouse. Please call me on my cell. I have a plea that starts at 2:00. Assistant U.S. Attorne From: (USAFLS) Sent: Wednesday, January 11 2012 11:27 AM To: (USAFLS); Subject: RE: Voluntary Production of Materials?I Let's shoot for 1:30. Are you available then, (USAFLS) From: (USAFLS) Sent: Wednesda January 11, 2012 11:22 AM To: (USAFLS); Subject: RE: Voluntary Production of Materials?' (USAFLS) I have calendar call at 1:00 p.m. I should be back by 1:30. From: (USAFLS) Sent: Wednesday, January 11, 2012 11:20 AM To: I. (USAFLS); (USAFLS) Subject: RE: Voluntary Production of Materials?' Sorry, first thing in the morning did not work out. Do you want to talk briefly now, or perhaps at 1:30? Alternatively, I can also call in after my doctor's appointment. Given the waits I often encounter there, that will likely be around 6:00 pm or so. From: (USAFLS) Sent: Tuesda January 10, 2012 11:15 AM To: (USAFLS); (USAFLS) Subject: RE: Voluntary Production of Materials?' 11 we could speak first thing in the morning, I would appreciate it. One of the reasons why I don't feel comfortable handling the discovery is because I am not familiar with the privilege defenses that we have to production. Many of the items that they have asked for seem to me to fall within, at the very least, attorney-client privilege and work product doctrine (for example, DRAFT victim notification letters, internal correspondence between AUSAs and DOJ attorneys, etc.) I also have a vague notion that there are "executive privilege" and "investigatory privilege" bars to EFTA00205495