Dorego 6 and Request to Glenwood 3 demand documents and communications concerning contact with Glenn Rink, Thomas Dwyer, Christopher McKenna, Defs. Glenwood Opp'n" refers to "Memorandum of Law in Opposition to Motions to Quash Subpoenas Served on Glenwood M-itnasementj Charles Dorego, and Steven Swarzman," ECF

ll have been a sham transaction in which Dorego paid no consideration, and Swarzman claimed fake losses in order to reap the tax benefits." (Defs.' Glenwood Opp'n,s at 5.) Defendants' only basis for making this argument appears to be Government notes from a conversation Swarzman had with the Government: "Sold