EFTA00029796.pdf

Type: pdf
Source set: data-set-8
Extracted text

From: 
To: 
• 
Cc:if 
" 
Subject: RE: Following up 
Date: Thu, 25 Jun 2020 22:45:04 +0000 
Attachments: Material_Witness_PA_4.02_Final 
sigmed.pdf 
CRM)" 
The MLAT is attached for reference, thanks. 
From: 
(USANYS).
> 
Sent: Thursda June 25, 2020 6:28 PM 
To 
(CRM) 
Cc: 
Subject: RE: Following up 
Thanks, 
I appreciate the concern and am open to working to address it, to the extent possible. We, of course, 
would never simply turn this material over to a civil litigant, as you suggest. The problem is, irrespective of our intent, this 
is not Rule 6 material (unless, of course, he testifies before a grand jury), and we are trying to be mindful of not simply our 
criminal case, but obligations we may have under other aspects of U.S. law, FOIA and/or Touhy, spring to mind, for 
example. Again, we never voluntarily turn this stuff over, and we frequently oppose FOIA requests and the like to the 
extent we can under the law. But particularly given the history and concern, we don't want to make promises we may not 
be able to keep. 
Do you by any chance have handy a copy of the MLAT itself (if not, certainly happy to locate myself, just figured you might 
have it already). I'd like to see what, if anything, the treaty says about this subject. 
From: 
CRM) 
Sent: Thursday, June 25, 2020 2:47 PM 
To: 
USANYS 
; 
) 
Cc 
Su ject: RE: Fo owing up 
Thanks. This is helpful. One clarification which they will seek - because it seems to loom 
large in their suspicions - is whether his statement will be provided to victims for purposes 
of civil litigation. I know this is not something that ordinarily happens (I don't think I have 
ever done this) - but I think we need to say something about that to move this forward. 
Maybe something like, "Absent a court order directing otherwise, the SDNY will not use or 
disclose the statement in any matter other than a criminal investigation, prosecution, or 
related asset forfeiture action initiated by the United States government." 
What do …
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