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From: '
To: '
"11.1.17)"
›,
(USANYS)"
Cc:
)"
I
(USANYS)"
Subject: FW: Redactions to MILs
Date: Wed, 03 Nov 2021 04:40:28 +0000
Attachments: Jury_Instructions_Govt_Proposed_Defense_Redlinesj2021.11.01].DOCX;
Jury_Instructions_Govt_Proposed_Defense_Redlines J2021.11.01]
Hey Chiefs,
They sent us the rest of their redline, if you'd like to take a look.
I've also attached a partial set of responses. I'll get you the rest ASAP tomorrow, but we're tight on timing, so here's about
half of it now. Two points about it:
1. I wasn't sure whether you wanted to see every change, so I've put comment bubbles even where I think we should
just accept the changes.
2. In their new redline as of tonight, they are proposing to do each count in order. We won't have time to implement
that by tomorrow, but we should think about whether to keep it as is or agree to their proposal.
This is due today (Wednesday), and the defense has significantly blow their deadline to get this to us. If it would help, we
can seek an extension on that basis.
Last, as you can see, they insist on putting our victims' names in filings. We are thinking of proposing to the defense that
they just note in a footnote their continued objection but stop using the names. Otherwise, we'd like to talk about going
to the Court. Their practice is (1) burdensome to make us redact all their filings, and (2) an invitation for us to miss
something and out a victim.
Thanks,
From: Christian Everdell <
Sent: Wednesday, November 3, 2021 12:19 AM
To:
Cc:
(USANYS)
<a;
Jeff Pagliuca
• Laura Menninger <a;
Subject: [EXTERNAL] RE: Redactions to MILs
Attached is the full redline of the RTCs. I made some changes to the sections I already sent you. Those are highlighted in
yellow. I will send you the verdict sheet later tonight.
Regarding the "Minor-Victim" terminology, I know the redactions are a pain, but it is still our position that there is no
need to anonymize them and we object to calling them both "minors" and "victims." So I can't agree to that.
Thanks,
EFTA00030638
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Chris
From:
Sent: Tuesday, November 2, 2021 6:35 PM
To: Christian Everdell
Subject: RE: Redactions to MILs
Hi Chris,
Just checking in on when you think you might have the rest of the RTC over to us.
Also, do you have any objection if we edit the places where your redline uses victim names to the "Minor Victim-X"
terminology? Our understanding is that we have to file this on ECF, and we just want to avoid having to redact anything.
Thanks,
From: Christian Everdell <
Sent: Tuesday, November 2, 2021 3:43 PM
To:
Subject: [EXTERNAL] Re: Redactions to MILs
Do you have a minute for a quick call about the jury instructions? Should take 5-10 mins.
Thanks,
Chris
Sent from my iPhone
On Nov 2, 2021, at 12:44 PM,
> wrote:
Counsel,
We're preparing a new version of the proposed redactions to the MILs that withdraw some of our proposals. Please let
us know which if any of your proposed redactions you would like to withdraw, and whether you would like to see our
version before we send it to the Court. In particular, please let us know by Thursday at 10 a.m. so we have some time
before this is due to the Court.
Thanks,
Assistant United States Attorney
Southern District of New York
Saint Andrews Plaza
New York, New York 10007
EFTA00030639
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From:
To:l
Cc:
Subject: RE: [EXTERNAL] Re: Scheduling
Date: Tue, 02 Nov 2021 21:38:04 +0000
Attachments: 2021.11.01JSP_Letter_to_USAO_re_Ru16_16_Disclosures_Redacted.pdf
First, I wanted to send along the defense's expert disclosure for your review. We can discuss tomorrow.
On travel arrangements, I have consulted with others internally and can approve the purchase of a business class ticket if
nothing else is available. You should attach this email to your Amtrak tickets when you submit for reimbursement.
Thanks,
From
Sent: Tuesday, November 2, 2021 4:49 PM
To:
Cc:
Subject: Re: [EXTERNAL] Re: Scheduling
Are you planning to call now?
On Tue, Nov 2, 2021 at 12:07 PM
wrote:
Yes, I can speak for 15 minutes between 4:45-5:00
Lisa
On Tue, Nov 2, 2021 at 11:54 AM
> wrote:
(USANYS) <
Hi
are you free to speak after 3 pm today briefly?
From:
Sent: ues ay, ovember 2, 2021 10:20 AM
To:
Cc:
Subject: Re: [EXTERNAL] Re: Scheduling
Hello
Thank you - these rates are fine for the hotel, but in order to stay within the rate limit, I need to book a non-
refundable rate. Please confirm the dates you would like me to be in NY next week as well as what dates you
anticipate working together for trial prep after the hearing (Thurs/Fri vs Fri/Sat). I need to move patients and would