EFTA00021532.pdf

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

From: 
(USANYS)" ci 
To: 
Cc: 
Subject: RE: motions under seal? 
Date: Fri, 02 Aug 2019 15:49:38 +0000 
As you know, the protective order distinguishes between all discovery and that marked "sensitive," and it is the sensitive 
discovery that cannot be publicly filed. El 
statements to law enforcement do not fall into the sensitive 
category, so they should be publicly filed. We'd ask that, consistent with the protective order, any sensitive discovery and 
references to cooperators be redacted in your public filings. Along the same lines, we noticed that you publicly filed four 
documents that were marked sensitive (Exhibits A through D to your cell site motion) in violation of the protective order. 
We will be asking the Court to remove them from the docket and you will need to refile. 
Assistant United States Attorney 
From: 
Sent: Friday, August 2, 2019 11:33 AM 
To: 
(USANYS) 
Cc:
Bachrach ([email protected]) <[email protected]>; [email protected] 
Subject: RE: motions under seal? 
.cl
>; Michael 
I don't think that will satisfy our concern about revealing the statements and certainly not something we can do today or 
easily. Nor do I want the extra work. 
Garden City, NY 11530 
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From: 
(USANYS) 
Sent: Friday. August 02 2019 11:26 AM 
To: 
Cc: 
Subject: RE: motions under seal? 
; Michael Bachrach (michaelembachlaw.com); bkoffskyesnet.net 
EFTA00021532


It is a little difficult to know what needs to be sealed/redacted in the abstract. Out of a…
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