- Subject (provided): Re: motions under seal?
- Header fields visible in image: From:, To:, Cc:
- All names and email addresses are redacted with black bars.
- One To recipient label includes “(USANYS)” (U.S. Attorney’s Office, S.D.N.Y.).
- Recipients appear in "Name" <address> format (angled brackets visible).
- Multiple recipients listed on both To and Cc lines.

Subject: Re: motions under seal?

Date: Fri, 02 Aug 2019 16:25:25 +0000

The email is dated Aug 2, 2019, and was sent at 12:10 PM by USANYS. The sender mentions emailing a motion later that day and writing the court on Monday. An address is provided: Garden City, NY 11530. Certain information has been redacted.

Key information from the email:

*   **Subject:** RE: motions under seal?
*   **From:** \[Name redacted]
*   **Sent:** Friday, August 2, 2019 12:07 PM
*   **To:** \[Names redacted] (USANYS)
*   **Cc:** \[Names redacted]
*   The email is from an Assistant United States Attorney.
*   The email discusses sealing documents and statements, referring to a court request. The sender expresses doubt about the legal basis for sealing the statements.

We will take care of that error and apologize for it.

I know that the statements are not marked as sensitive by the Government but for obvious reasons we don't want to file those publically. Thus our request. If the government won't consent then, we will serve you via email and hold off filing it until we can get the court to rule.

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- Line 3: partially redacted, visible text: "Garden City, NY 11530"
- Line 4: fully redacted (long black bar)
- Line 5: fully redacted (short black bar)

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This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments

Email details:
*   **From:** [Redacted], (USANYS), [mailto:Redacted]
*   **Sent:** Friday, August 02, 2019 11:50 AM
*   **To:** [Redacted]; [Redacted]
*   **Cc:** [Redacted]; [Redacted]; [Redacted]
*   **Subject:** RE: motions under seal?



As you know, the protective order distinguishes between all discovery and that marked "sensitive," and it is the sensitive discovery that cannot be publicly filed. statements to law enforcement do not fall into the sensitive category, so they should be publicly filed. We'd ask that, consistent with the protective order, any sensitive discovery and references to cooperators be redacted in your public filings. Along the same lines, we noticed that you publicly filed four documents that were marked sensitive (Exhibits A through D to your cell site motion) in violation of the protective order. We will be asking the Court to remove them from the docket and you will need to refile.

Assistant United States Attorney

| Field | Extracted content |
|---|---|
| From | [REDACTED] |
| Sent | Friday, August 2, 2019 11:33 AM |
| To | [REDACTED]; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]> |
| Cc | [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] |
| Subject | RE: motions under seal? |

I don't think that will satisfy our concern about revealing the statements and certainly not something we can do today or easily. Nor do I want the extra work.

- Visible text: "Garden City, NY 11530" (blue/hyperlink)
- Other content: five lines fully redacted (black bars) — likely name, street address, and contact info
- Context: appears to be an email/signature block with a confidentiality/attorney‑client transmittal notice visible in surrounding text

This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments

| Field | Extracted text |
|---|---|
| Notice (top) | "This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments" |
| From | [REDACTED], [REDACTED] (USANYS) [mailto:[REDACTED]] |
| Sent | Friday, August 02, 2019 11:26 AM |
| To | [REDACTED] |
| Cc | [REDACTED]; [REDACTED]; [REDACTED] (multiple recipients redacted) |
| Subject | RE: motions under seal? |

Notes: Sender, recipients and email addresses are redacted in the image.

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It is a little difficult to know what needs to be sealed/redacted in the abstract. Out of an abundance of caution, can you file the documents with any reference to evidence/discovery and cooperators redacted? We can then review the unredacted version and discuss what, if anything, can be unredacted for the public version.

Key information from the image:

*   Sender: \[REDACTED]
*   Recipient: \[REDACTED] (USANYS)
*   CC: \[REDACTED]
*   Date: August 2, 2019, 11:03 AM
*   Subject: motions under seal?
*   Sender Title: Assistant United States Attorney



Our motions will be ready to go out in a few hours., One is straight forward legal argument about the cell tower data, which we don't have a problem filing. The other motion deals with the statements to the police and by necessity we discuss the statements in detail. We also discuss some of the discovery and the cooperating witnesses. What is the Government position about filing that motion under seal?

Also, affidavit hasn't been signed because the only regular access to a notary are members of his legal team and [ ]
we don't want to witness his signature. We will have him sign it through whatever the process is at MCC or in open
court at our next appearance.

- Document element: redacted address block / letterhead
- Visible text: "Garden City, NY 11530"
- Redactions: 3 blacked-out lines above the visible line; 2 blacked-out lines below it (total 5 redacted lines)
- Likely content: name/street lines removed; remaining visible line is city and ZIP (Garden City, NY 11530)

This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments

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