EFTA00030638.pdf

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

From: ' 
To: '
"11.1.17)" 
 
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(USANYS)" 
Cc:
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(USANYS)"
Subject: FW: Redactions to MILs 
Date: Wed, 03 Nov 2021 04:40:28 +0000 
Attachments: Jury_Instructions_Govt_Proposed_Defense_Redlinesj2021.11.01].DOCX; 
Jury_Instructions_Govt_Proposed_Defense_Redlines J2021.11.01] 
Hey Chiefs, 
They sent us the rest of their redline, if you'd like to take a look. 
I've also attached a partial set of responses. I'll get you the rest ASAP tomorrow, but we're tight on timing, so here's about 
half of it now. Two points about it: 
1. I wasn't sure whether you wanted to see every change, so I've put comment bubbles even where I think we should 
just accept the changes. 
2. In their new redline as of tonight, they are proposing to do each count in order. We won't have time to implement 
that by tomorrow, but we should think about whether to keep it as is or agree to their proposal. 
This is due today (Wednesday), and the defense has significantly blow their deadline to get this to us. If it would help, we 
can seek an extension on that basis. 
Last, as you can see, they insist on putting our victims' names in filings. We are thinking of proposing to the defense that 
they just note in a footnote their continued objection but stop using the names. Otherwise, we'd like to talk about going 
to the Court. Their practice is (1) burdensome to make us redact all their filings, and (2) an invitation for us to miss 
something and out a victim. 
Thanks, 
From: Christian Everdell < 
Sent: Wednesday, November 3, 2021 12:19 AM 
To: 
Cc: 
(USANYS) 
<a; 
Jeff Pagliuca 
• Laura Menninger <a; 
Subject: [EXTERNAL] RE: Redactions to MILs 
Attached is the full redline of the RTCs. I made some changes to the sections I already sent you. Those are highlighted in 
yellow. I will send you the verdict sheet later tonight. 
Regarding the "Minor-Victim" terminology, I know the redactions are a pain, but it is still our position that there is no 
need to anonymize them and we object to calling the…
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