Subject: RE: US v. Maxwell - [Request for 120 or 180 -day Adjournment of Trial]

- From: [REDACTED] <[REDACTED]>  
- To: multiple recipients (names redacted); at least some recipients labeled “(USANYS)”  
- Cc: multiple recipients (names redacted); at least one labeled “(USANYS)”  
- Format shown: quoted display names followed by angle-bracketed addresses, most content blacked out/ redacted.

Subject: RE: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial]

Date: Thu, 22 Apr 2021 20:09:31 +0000

Attachments: 2021-04-22 Gov't_letter_re_GM_request_for_adjournment_v4.docx; 2021-04-
22 letter_re _request_to_file_under_seal.docx

Thanks very much, [REDACTED]. Attached please find a revised draft incorporating your edits. I've also attached a draft sealed letter informing AJN of [REDACTED].

Key information from the image:

*   **From:** (USANYS)
*   **Sent:** Thursday, April 22, 2021, 3:06 PM
*   **To:** (USANYS)
*   **Cc:** (USANYS)
*   **Subject:** RE: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial]

Happy to look at another version before filing, thanks very much.

| Field | Value |
|---|---|
| Document type | Email header (screenshot) |
| From | [REDACTED] <[redacted]> |
| Sent | Thursday, April 22, 2021 1:32 PM |
| To | Multiple recipients (names/emails redacted); some entries labeled “(USANYS)” |
| Cc | Multiple recipients (redacted); some entries labeled “(USANYS)” |
| Subject | RE: US v. [REDACTED] - [Request for 120 or 180-day Adjournment of Trial] |
| Other visible note | “Draft response attached.” |
| Visual notes | Most names and email addresses blacked out with solid redaction blocks; multiple recipients listed.

Draft response attached.

From: [REDACTED] <[REDACTED]>
Sent: Thursday, April 22, 2021 12:14 PM
To: [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>
Subject: FW: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial]

FYI. Our response is due at 5 today.

Email communication:
*   **From:** Laura Menninger
*   **Sent:** Thursday, April 22, 2021 11:22 AM
*   **To:** (redacted)
*   **Cc:** (redacted), Jeff Pagliuca, Bobbi Sternheim

EFTA00032783

([REDACTED])' < [REDACTED>; Nicole Simmons < [REDACTED>
Subject: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial]

Judge Nathan -

Pursuant to this Court's Order of April 20, 2021 (Dkt. 221), attached please find counsel's Letter Motion for an Adjournment of the trial.

Counsel for Ms. Maxwell request redaction of their other clients' names and case numbers from this Letter Motion pursuant to Rule of Professional Conduct 1.6 which prohibits lawyers from revealing confidential information related to a client even where that information is publicly available. See In Re. Anonymous, 654 N.E. 2.d. 1128 (Ind. 1995) (lawyer violated Rule 1.6 by disclosing information relating to representation of client, even though information "was readily available from public sources and not confidential in nature"); In re Bryan, 61P.3d 641 (Kan. 2003) (lawyer violated Rule 1.6 by disclosing, in court documents, existence of defamation suit against former client); State ex reL Okla. Bar Ass'n v. McGee, 48 P.3d 787, 791 (Okla. 2002) (a lawyer's duty of confidentiality attaches "to all information relating to the representation, whatever its source").

Upon direction of the Court, counsel will file either the redacted or unredacted version of this letter on the public docket.

Best regards,

Laura Menninger

Laura A. Menninger | Partner
Haddon, Morgan & Foreman, P.C.

EFTA00032784