EFTA00028423.pdf

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

From: 
To: "Martin G. Weinberg" C
Cc: 
Weingarten 
Subject: RE: Protective Order 
Date: Wed, 24 Jul 2019 21:58:36 +0000 
Attachments: 2019-07-24, JE,_protective_order_for_discoveryiRMB).pdf 
"'Miller, Michael"' 
,'Reid 
Marty, 
Attached is a revised protective order, which incorporates the edits from our discussion today. If there are any issues or 
questions, please let us know. Otherwise, if you could please send us a signed copy, we'll take care of submitting it to the 
Court. 
Thanks, 
From: Martin G. Weinberg <MII
> 
Sent: Wednesday, July 24, 2019 10:51 AM 
To: 
Cc: 
'Miller, Michael' ,ei; 
'Reid Weingarten' <fl 
Subject: RE: Protective Order 
'Martin Weinberg' < 
Hi 
Some points for discussion or consideration re draft Protective Order: 
Pg 2, line 2 - we consent to the entry of the Order but not necessarily all of the averments made by the Government in 
support of the Order 
Pg 3 - par 2 - we need to distinguish between providing discovery electronically to others on the defense team (encrypt or 
password protected) and providing hard copies of discovery for the purpose of review by counsel or by counsel or others 
on defense team with the defendant at MCC 
Pg 3 - par 3 -5 - these obligations should extend to Govt as well as defense 
Pg 3 - par 4 - are you precluding public discussion of identity of witnesses already known to the defense i.e. known 
independent of the discovery 
Pg 3/4 - par 5 - are you asking for redacted public filings or the entire filing being filed under seal - we could redact any 
quoting of the discovery or attaching of the discovery if that suffices 
Pg 4-5 par 7 - there is no need for allegations of potential obstruction or harm to witnesses in this case - I would request 
that such language be redacted as unnecessary if we are not contesting the clause. Please advise if the Govt intends to 
mark all 302s as "confidential" or just the identifying info (names, addresses, etc). 
Par 12 - defense should be allowed to retain discovery t…
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