- Subject (from context): "RE: motions under seal?"
- From: [REDACTED] (USANYS) <[REDACTED]> — sender name/email fully redacted; "(USANYS)" shown after name.
- To: multiple recipients; entries fully redacted (one shows a quoted display name followed by a redacted email in angle brackets).
- Cc: three long entries, each fully redacted (black bars).
- Visual note: all names and email addresses are obscured by black redaction bars.

Subject: RE: motions under seal?

Date: Fri, 02 Aug 2019 15:26:25 +0000

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.



Assistant United States Attorney

| Field | Value |
|---|---|
| Subject | motions under seal? |
| From | [redacted] |
| Sent | Friday, August 2, 2019 11:03 AM |
| To | Multiple recipients (addresses redacted); one recipient labeled “(USANYS)” |
| Cc | One long redacted block (addresses redacted)

Subject: motions under seal?



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: redacted address/contact block (document snippet)
- Visible text: "Garden City, NY 11530"
- Redactions: six black bars obscuring preceding and following lines (likely name, street address, and other contact details)

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