EFTA00022486.pdf

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

From: 
(USANYS)" < 
To: '
)" C 
Subject: FW: US v. Maxwell, 20 Cr. 330 (AJN) - meet and confer 
Date: Thu, 29 Apr 2021 00:35:54 +0000 
Attachments: 2021-04-30 Gov't Letter to Manley.docx 
>, 
11 
MC — I can join you for a call on Manley's letter. I put together the start of a letter (attached) based on your notes in the 
calendar invite and some other additions, but of course I imagine this may change based on our convo with counsel. 
From: Laura Menninger 
Sent: Wednesday, April 28, 2021 6:13 PM 
To: 
) 
Bobbi Sternheim 
'BOBBI C STERNHEIM' 
Jeff Pagliuca 
Cc: 
Mark S. Cohen 
)4S 
Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN) - meet and confer 
(USANYS)
Thanks for reaching out. We probably are best served by sending you our position on defense disclosures by email. We 
should be able to send that by Friday and can schedule a time to talk thereafter if you wish, with an eye towards the joint 
filing on Monday. 
We will confer with the team on the Speedy Trial issue and also get back to you on that. 
Lastly, do you want to discuss anything regarding Mr. Manley's application to the Court? I believe we are to discuss and 
then you are to write the Court by Friday. I am free tomorrow afternoon to discuss if you wish. 
Thanks, 
Laura 
Laura A. Menninger I Partner 
Haddon. Morgan & Foreman, P.C. 
From: 
c
› 
Sent: Tuesday, April 27, 2021 10:22 PM 
To: 
Bobbi Sternheim < 
; 'BOBBI C 
STERNHEIM' 
Cc: 
) 
; Laura Menninger < 
>; Jeff Pagliuca 
Mark S. Cohen 
Subject: US v. Maxwell, 20 Cr. 330 (AJN) - meet and confer 
Counsel, 
(USANYS) 
Per Judge Nathan's Order (docket number 250), is there a time this week when you would be available for a call to meet 
and confer regarding a proposed schedule for defense disclosure of witness statements pursuant to Rule 26.2? Or if you 
EFTA00022486


would prefer to confer by email, would you please let us know your position? 
Additionally, we intend to submit a letter to Judge Nathan requesting that time under the Speedy Trial Act be excl…
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