EFTA00021918.pdf

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

From: ' 
 
cti 
To: Christian Everdell 
 " 
II 
Cc: "Mark S. Cohen" 
, Jeff Pagliuca ci 
'Laura Menninger'
Subject: RE: Protective Order 
Date: Sat, 25 Jul 2020 20:13:13 +0000 
Attachments: 2020-07-25,_GM,_protective_order,_clean_version.docx 
Inline-Images: image001.png; image002jpg 
Chris, 
Following up on our discussion last night, attached please find a revised draft protective order. As we discussed, although 
this does not represent a version that has been formally approved internally at our Office, it is an effort to include the 
updates and edits we talked through yesterday. I believe this should represent what we addressed, but I also realize that 
we've revised some aspects that you mentioned you'd need to further consider, and there is some new proposed 
language in areas you suggested we clarify, so I expect it may be useful to chat again once you've reviewed. All that said, 
we wanted to get you the revised version quickly, and I'm happy to discuss again, including anytime this weekend if that's 
helpful, to go through any outstanding issues. 
thanks, 
From: Christian Everdell 
Sent: Wednesday, July 22, 2020 20:13 
To: 
•c
> 
C 
Cc: Mark S. Cohen ,:
); Jeff Pagliuca < 
'Laura Menninger' 
Subject: Protective Order 
Attached is a revised draft of the defense's proposed Protective Order (including a redline against the government's 
original draft and a clean version). We did our best to incorporate the points we discussed on our last call on Monday, July 
20 and to find points of common ground and agreement. Please let us know by 5pm tomorrow whether the attached 
draft is acceptable to the Government. 
Regards, 
Chris 
Christian Everdell 
COHEN & GRESSER LLP 
800 Third Avenue 
New York. NY 10022 
EFTA00021918


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