EFTA00029339.pdf

Type: pdf
Source set: data-set-8

Extracted text

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MAURICE A. BORDEN
JEFFREY L. JOCKS
ICARIUE A. ZEITS
RONALD W. SONDE!. or cowau.
JOHN P. RACINE. JR.. or conic
W. PETER DOREN. 0 cOuNsa
N E V 5
May 13, 2021
Assistant United States Attorney
Southern District of New York
One St. Andrew's Plaza
New York, NY 10007
310 WEST FRONT STREET
SUITE 300
TRAVERSE CITY. MICHIGAN 49684
TEL (231) 947-0400
FAX (231) 947-0748
www.sondetracintcom
Re: Interlochen Center for the Arts — Grand Jury Subpoena dated March 26, 2021
Dear a
As you know, I represent Interlochen Center for the Arts ("Interlochen"). Enclosed
please find executed custodian certifications along with a document production on behalf of
Interlochen in response to the subpoena duces tecum that was served by your office on the
custodian of records for Interlochen. The enclosed flash drive includes those responsive
documents with a bates range of INT000001 through INT000096.
Consistent with our prior communications, Interlochen is committed to cooperating fully
with your office.
The submission of this letter and the materials enclosed herewith is without prejudice to,
and with full reservation of, all privileges, rights, and protections. Interlochen requests that this
letter and the materials attached hereto be treated as exempt from disclosure, under the Freedom
of Information Act, 5 U.S.C. § 552 ("FOIA"), and as confidential pursuant to 28 C.F.R. § 16.8.
We submit these materials to you with the understanding that your office's request for
this information is relevant and material to a valid law enforcement purpose. We further submit
these materials to you with the understanding that they will remain confidential unless and until
they are made public by the Court.
Finally, we submit these materials to you with the understanding that, in the event that
any privileged or work-product protected documents are produced, inadvertent or otherwise,
your office will promptly destroy each copy of any s…

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