Epstein Project

EFTA00023462.pdf

Type
pdf
Source set
data-set-8

Original source

Extracted text

From: ' 
To: Christian Everdell <CEverdell CohenGressencom>, " 
, BOBBI C 
STERNHEIM <[email protected]>, Laura Menninger <[email protected]>, 
Jeff Pagliuca ipagliuca®hmflaw.com> 
Cc: 
Subject: 
Date: 
Attachments: 
RE: Redactions: Government motion in limine 
Sat, 30 Oct 2021 00:11:41 +0000 
2021-10-29_Govit_letter_re_Proposed_Redactions_to_MILs_vl.docx 
Thanks, Chris. I know you're in the process of filing, but in the meantime, here's a draft joint letter. 
Thanks, 
From: Christian Everdell <[email protected]> 
Sent: Friday, October 29, 2021 7:55 PM 
To: 
STERNHEIM <[email protected]>; Laura Menninger <[email protected]>; Jeff Pagliuca 
<[email protected]> 
Cc:
Subject: (EXTERNAL] RE: Redactions: Government motion in limine 
All — 
; BOBBI C 
I have confirmed that the government has incorporated all of the defense's proposed redactions within the government's 
proposed redactions. We do not have any more to add. For the record, we oppose the government redactions that are 
additional to the defense's redactions. 
We will now file the defense's motions and exhibits, as redacted/sealed, and then wait for you to file the government's 
response. It may take a little time to get them all filed, so bear with me. 
Thanks, 
Chris 
From: 
Sent: Friday, October 29, 2021 6:45 PM 
To: 
; Christian Everdell <[email protected]>• BOBBI C 
STERNHEIM <[email protected]>• Laura Menninger <Imenninge
hmflaw.com>• Jeff Pagliuca 
<[email protected]>
Cc: 
Subject: RE: Redactions: Government motion in limine 
All, 
For filing purposes, attached are redacted versions of the defendant's motions and exhibits, the government's omnibus 
opposition, and the defendant's omnibus reply. Below are our notes on which exhibits should be sealed. Please let us 
know if you would like to add any redactions or if you have any questions. 
EFTA00023462


Defense Motions 
Sealed 
The following exhibits should be sealed 
• Exhibit A to Motion 4 (grand jury testimony) 
…

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