EFTA00028423

From: To: "Martin G. Weinberg" C Cc: "'Miller, Michael"' ,'Reid Weingarten Subject: RE: Protective Order Date: Wed, 24 Jul 2019 21:58:36 +0000 Attachments: 2019-07-24,JE,_protective_order_for_discoveryiRMB).pdf Marty, Attached is a revised protective order, which incorporates the edits from our discussion today. If there are any issues or questions, please let us know. Otherwise, if you could please send us a signed copy, we'll take care of submitting it to the Court. Thanks, From: Martin G. Weinberg <MII > Sent: Wednesday, July 24, 2019 10:51 AM To: 'Martin Weinberg' < Cc: 'Miller, Michael' ,ei; 'Reid Weingarten' <fl Subject: RE: Protective Order Hi Some points for discussion or consideration re draft Protective Order: Pg 2, line 2 - we consent to the entry of the Order but not necessarily all of the averments made by the Government in support of the Order Pg 3 - par 2 - we need to distinguish between providing discovery electronically to others on the defense team (encrypt or password protected) and providing hard copies of discovery for the purpose of review by counsel or by counsel or others on defense team with the defendant at MCC Pg 3 - par 3 -5 - these obligations should extend to Govt as well as defense Pg 3 - par 4 - are you precluding public discussion of identity of witnesses already known to the defense i.e. known independent of the discovery Pg 3/4 - par 5 - are you asking for redacted public filings or the entire filing being filed under seal - we could redact any quoting of the discovery or attaching of the discovery if that suffices Pg 4-5 par 7 - there is no need for allegations of potential obstruction or harm to witnesses in this case - I would request that such language be redacted as unnecessary if we are not contesting the clause. Please advise if the Govt intends to mark all 302s as "confidential" or just the identifying info (names, addresses, etc). Par 12 - defense should be allowed to retain discovery through the filing date of a 2255 Reid, Mike may have additional questions, points. Available after 1 to discuss. Thanks Marty Martin G. Weinberg, Esq. EFTA00028423 Boston. MA 02116 This Electronic Message contains information from the Law Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee only. If you are not the addressee, please note that any disclosure, copying, distribution, or use of the contents of this message is prohibited. From: Sent: Tuesday, July 23, 2019 7:02 PM To: Martin G. Weinberg <=. > Cc: Subject: Protective Order Marty, Following up on our conversation this morning, I'm attaching the proposed protective order we discussed. If you have any questions, or think it would be productive to schedule a call to discuss, please let us know. Thanks, Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 EFTA00028424