From:
To:
Subject: FW:
Date: Thu, 29 Apr 2021 19:01:06 +0000
Attachments: 2021-04-30 _Gov't_Letter to Manley.v3.docx
Updated version attached. Let me know if you're good with this, and I'll send a pdf to defense counsel. FYI I've changed
the cc line, since BSF is now in theory counsel of record in the case, and we're not sending this to them.
From: (USANYS)
Sent: Thursday, April 29, 2021 2:45 PM
To: (USANYS)
Cc: >; (USANYS) <
Subject: RE:
nice work on this, my edits are attached.
From:
Sent: Thursday, April 29, 2021 11:01 AM
To: (USANYS) (USANYS)
Cc: >; (USANYS)
)<
Subject: RE:
In case it's useful while we're troubleshooting this issue today, I'm attaching the working draft. We'll let you know if we
find additional authorities on this or obtain different guidance
From:
Sent: Thursday, April 29, 2021 10:32 AM
To: (USANYS) >; (USANYS) < >;
(USANYS)
Cc: >; (USANYS) S;
Subject:
We're working on drafting a letter in response to the attached, and wanted to give you a heads up. We hope to have a
draft for you this afternoon, in the hopes of sending the draft to defense counsel tonight as part of the meet-and-confer
directed by Judge Nathan. I think that leaves sufficient time for filing tomorrow.
Although we're mindful of third party privacy interests, for non-parties who are neither witnesses nor victims in the case, I
do have concerns about entertaining redaction/intervention requests, given the high volume of people who may ask to be
heard or assert a right to review and redact documents if this were entertained.
Thanks,
EFTA00013434
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00013435