From:

To:

Subject: RE: Letter regarding discovery attached.
Date: Wed, 12 Aug 2020 15:59:18 +0000
Attachments: 2020-08-12, GM,_letter_to_defense_counsel_re_discovery.docx
Inline-Images: image001.jpg

Draft letter response attached. Let me know if you have any revisions before I send to the chiefs.

From:
Sent: Monday, August 10, 2020 2:02 PM
To:
Subject: RE: Letter regarding discovery attached.



Thanks for sending, | I agree with this approach, though defer to

if she's handling, and thanks in advance. On

the last point: I do think we have a firm view that they should not be filing our discovery materials in civil cases. I don't

care about the substance of these particular documents, but I think we agree that is an important aspect of the protective

order to assert, both in this instance and in general, so this issue doesn't continue to crop up.

From:

Sent: Monday, August 10, 2020 11:37 AM
To:

Cc:

Subject: FW: Letter regarding discovery attached.





I think is particularly swamped this week - can you please take the lead on whatever we're going to do with this

(i.e., presumably whatever the chiefs decide)? My personal vote would be to tell them that the protective order explicitly

precludes the use of criminal grand jury materials in Maxwell's civil cases, and the materials are sealed because they

relate to an ongoing grand jury investigation and they should feel free to raise the issue with Nathan and we'll respond.

(And I would think our response could basically be a copy-paste of the letter I wrote to Netburn.) We could also note in

our response to Jeff and Laura, if we wanted to, that given their awareness of the materials, we assume they will retract

the obviously false claims about government malfeasance.

All that said, I also wouldn't object if they just want to allow them to file these materials under seal; I don't think it matters hugely. If we could have resolved (et al) by now, none of this would be an issue.

thanks,

From: Jeff Pagliuca <jpagliuca@hmflaw.com>
Sent: Sunday, August 09, 2020 18:56
To:

Cc: Laura Menninger <lmenninger@hmflaw.com>; Christian Everdell <CEverdell@CohenGresser.com>; Mark S. Cohen <mcohen@CohenGresser.com>; Nicole Simmons <nsimmons@hmflaw.com> Subject: Letter regarding discovery attached.

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Dear Counsel,

Please see attached conferral letter.

Jeff



Jeffrey S. Pagliuca
Haddon, Morgan and Foreman, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Main 303.831.7364 FX 303.832.2628
jpagliuca@hmflaw.com
www.hmflaw.com

mation that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you

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