From:

To:

Subject: FW: Meet and Confer

Date: Mon, 22 Mar 2021 23:43:30 +0000

Attachments: 2021.02.26_Government_Omnibus_Opposition_to_Maxwell_Defense_Motions_FINAL_(Pr
oposed Redactions_Per_Order_and_Defense_Requested_Redaction).pdf; 2021-03-
22_GM_letter_re_pre-trial_opposition_redactions.docx

Inline-Images: image001.jpg; image002.jpg

Here is a draft letter to the Court. I'm going to send to the chiefs in 10 minutes so please let me know if you have any edits.

The image is completely blacked out.

Subject: RE: Meet and Confer



Judge Nathan agreed with us that sections of the deposition transcripts that appear unredacted in the publicly filed indictment should still be redacted in your opposition because they were sealed in the defamation case. The redactions we are proposing refer to those sections. So the fact that the language appears in the indictment does not mean it should not be redacted.

That said, to move this along, we will preserve this objection and raise it with the Court at a later time, if we choose to. However, we do ask that you redact "[Minor Victim-2]" at the bottom of page 134 so that it is consistent with the redactions ordered by Judge Nathan on the top of the same page.

Thanks,

Chris

Subject: RE: Meet and Confer

Chris,

We have confirmed that our proposed redactions to Exhibit 11 and those you circulated to Exhibit 11are the same. As to your newly proposed redactions, we understand that you are requesting that we redact portions of our brief that either quote or generally refer to unredacted portions of your publicly filed opening brief (Dkt. 136 at pages 14 to 17) or language contained in the publicly filed indictment. We don't understand why you are requesting that this language now be sealed. Can you please explain your position?

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Thanks,

## Subject: RE: Meet and Confer



I believe we agree on the redactions to Exhibit 11. I have attached our proposed redacted version of Exhibit 11. I have checked it against yours and I believe they track exactly, but maybe you could double check. We also agree that no redactions to the cover letter are necessary. We also confirm that you should keep the redactions on pp. 118-119.

We also noticed that on pages 130-134 of the opposition brief there are a few quotations and other references to testimony in the civil case that are still sealed. In light of Judge Nathan's order, we think those should be redacted as well. We have attached the relevant pages. The additional redactions are noted in red boxes.

Please let me know if you want to discuss further.

Thanks,

## Chris

Subject: RE: Meet and Confer

Chris,

Thanks for your email. In accordance with Judge Nathan's order, we are writing to confer regarding Exhibit 11 and your cover letter dated March 9, 2021. Attached please find proposed redactions to Exhibit 11. We do not believe any redactions are necessary to your cover letter.

We intend to the file the brief with the redactions as set forth in Judge Nathan's March 18, 2021 order, attached here for your convenience. We note that the redactions contained on pages 118 to 119 redact quotations from and references to a document that you filed under seal (Exhibit H). We understand that the quoted portions of that document are also under seal on the civil docket before Judge Preska. Given those facts, we wanted to double check with you to see whether you in fact want those redactions removed. We will defer to you on whether these should be redacted.

Best,

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Subject: Meet and Confer

Per Judge Nathan's order, we need to meet and confer today about proposed redactions to Exhibit 11 of your opposition and to our letter dated March 9, 2021regarding redactions. We are free from now through the rest of the afternoon. Please let us know what works for you.

Regards,
Chris

Christian R Everdell

## COHEN & GRESSER LLP



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