- Type: Email header (From, To, Cc)
- Subject (from surrounding text): "RE: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial]"
- Visible tokens: "From:", "To:", "Cc:", angle brackets for addresses
- Redaction: all names and email addresses obscured by black bars
- Other visible annotation: "(USANYS)" appears after some redacted names
- Structure: multiple comma-separated recipients in To and Cc lines (several addresses redacted)

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

Date: Thu, 22 Apr 2021 19:06:28 +0000

Attachments: 2021-04-22_Gov't_letter_re_GM_request_for_adjournment_v3.docx.rd.docx

Thanks this is well done, and my edits are attached. As you'll see, I suggested

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

| Field | Value |
|---|---|
| From | [redacted] |
| Sent | Thursday, April 22, 2021 1:32 PM |
| To | [multiple recipients — redacted] (several show “(USANYS)” next to recipients) |
| Cc | [multiple recipients — redacted] (one or more show “(USANYS)”) |
| Subject | RE: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial] |
| Context line (above image) | "Happy to look at another version before filing, thanks very much." |
| Attachment note (below image) | "Draft response attached." |

Draft response attached.

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

Surrounding text: "Draft response attached. FYI. Our response is due at 5 today."

FYI. Our response is due at 5 today.

| Field | Content |
|---|---|
| From | [redacted sender] |
| Sent | Thursday, April 22, 2021 11:22 AM |
| To | [redacted recipient list] |
| Cc | [multiple redacted recipients; includes an entry labeled “(USANYS)” and additional individual recipients] |
| Subject | US v. [redacted] - [Request for 120 or 180-day Adjournment of Trial] |
| Additional context | Header screenshot with extensive redactions; timestamp and subject are clear.

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

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1.6 by disclosing, in court documents, existence of defamation suit against former client); State ex reL Okla. Bor 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.

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