EFTA00020670.pdf

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

From: 
To: 
Cc: 
Subject: RE: United States v. Maxwell, 20 Cr. 330 (AJN) 
Date: Mon, 27 Jul 2020 22:26:28 +0000 
Attachments: GM,_protective_order,_clean_version.docx 
Attached is a Word version of the proposed protective order we submitted to the Court. In regards to your prior email, it 
sounds like it would be a more productive discussion after you have had the chance to review the redline of our proposed 
order. So we propose a call at 9:30am tomorrow morning. Let us know if that works for you and I will circulate a dial-in. 
Thanks, 
From:  
Sent: Monda Jul 27 2020 5:43 PM 
To: 
Cc: 
Subject: RE: United States v. Maxwell, 20 Cr. 330 (MN) 
MR 
We also request that the defense provide the Government with a Word version of its proposed protective order 
submitted to the Court earlier today. We are not able to run a redline using the filed version. 
Regards, 
From: 
Sent: Monday, July 27, 2020 16:43 
To: 
Cc: 
Subject: RE: United States v. Maxwell, 20 Cr. 330 (AJN) 
Pursuant to the Court's Order of this afternoon, we write to schedule a telephonic meet and confer on issues relating to a 
protective order in the above-captioned case. Please let us know what time you are available today between 5:00 p.m. 
and 8:00 p.m., or tomorrow between 9:00 a.m. and 1:00 p.m. In particular, it would be helpful to get the defendant's 
current position on the following: 
- 
Whether you are aware of any case in any federal district in which a protective order was entered in a criminal 
case that prevented the Government from showing its own documents to prospective witnesses or their counsel 
without requiring restrictions upon those witnesses and their counsel; 
EFTA00020670


Whether you are able to describe any expected reason why it would be necessary or useful for the defendant to 
reference by name — rather than by pseudonym or other anonymized identifier — any victim in a public statement 
or publicly-docketed filing (and rather than by sealed filing, if such named identifica…
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