Assistant United States Attorney Southern District of New York New York. NY 10007 From: Sent: Tuesday, August 18, 2020 3:19 PM To: Christian Everdell Cc: Mark S. Cohen Subject: RE: Discovery Chris, ; Thomas J. Powers ) ; Jeff Pagliuca 'Laura Menninger' The four Bates ranges you've identified are flight records produced by airline companies pursuant to subpoenas that requested flight records dating back to the 1990s. We have redacted flight information for recent flights (within the past decade) that substantially post-date the offense conduct. This information is not subject to disclosure under Rule 16. The protective order does not expand the scope of discovery; rather, it permits us to make disclosures of relevant materials with certain protections. If you have specific concerns, or if there is a particular reason you believe this material is subject to disclosure, please let us know if you'd like to discuss this further. If there are other specific redactions that you have questions about, please let us know. Some materials were produced to us in redacted format, so it's helpful for us to discuss specific Bates ranges. Best, From: Christian Everdell Sent: Tuesday, August 18, 2020 12:33 AM To: ) Cc: Mark S. Cohen Thomas J. Powers Su ject: RE: Discovery Jeff Pagliuca 'Laura Menninger' We have not compiled a complete list of redacted documents. But below are some samples Bates ranges that contain redactions. • SDNY_GM_00000977 —SDNY_GM_000001012 (American Airlines records) • SDNY_GM_00004650 —SDNY_GM_000046S5 (Delta Airlines records) EFTA00074700