EFTA00019474

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From: To: Subject: FW: Meet and Confer Date: Mon, 22 Mar 2021 23:43:30 +0000 Attachments: 2021.02.26_Govemment_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: image00 Ljpg; 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. 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 r Chris, We have confirmed that our proposed redactions to Exhibit 11 and those you circulated to Exhibit 11 are 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 unre