EFTA00085080.pdf

From: Christian Everdell To: ' Cc: USANYS , Jeff Pagliuca 1pagliuca&mflaw.com>, "Laura Menninger" <[email protected]>, "[email protected]" <[email protected]> Subject: [EXTERNAL] RE: Redactions to MILs Date: Wed, 03 Nov 2021 05:27:10 +0000 Attachments: Verdict_Sheet_Govt_Proposed_Defense_Redlines_[2021.10.29].DOCX Attached is the redlined version of the verdict sheet. Thanks, Chris From: Christian Everdell Sent: Wednesday, November 3, 2021 12:19 AM To: 11 )1 Cc: (USANYS) >; Jeff Pagliuca <[email protected]>; Laura Menninger <[email protected]>; [email protected] Subject: RE: Redactions to MILs Attached is the full redline of the RTCs. I made some changes to the sections I already sent you. Those are highlighted in yellow. I will send you the verdict sheet later tonight. Regarding the "Minor-Victim" terminology, I know the redactions are a pain, but it is still our position that there is no need to anonymize them and we object to calling them both "minors" and "victims." So I can't agree to that. Thanks, Chris From: Sent: Tuesday, November 2, 20216:35 PM To: Christian Everdell Subject: RE: Redactions to MILs Hi Chris, Just checking in on when you think you might have the rest of the RTC over to us. EFTA00085080 Also, do you have any objection if we edit the places where your redline uses victim names to the "Minor Victim-X" terminology? Our understanding is that we have to file this on ECF, and we just want to avoid having to redact anything. Thanks, From: Christian Everdell < Sent: Tuesday, November 2, 2021 3:43 PM To: Subject: [EXTERNAL] Re: Redactions to MILs Do you have a minute for a quick call about the jury instructions? Should take 5-10 mins. Thanks, Chris Sent from my iPhone On Nov 2, 2021, at 12:44 PM, > wrote: Counsel, We're preparing a new version of the proposed redactions to the MILs that withdraw some of our proposals. Please let us know which if any of your proposed redactions you would like to withdraw, and whether you would like to see our version before we send it to the Court. In particular, please let us know by Thursday at 10 a.m. so we have some time before this is due to the Court. Thanks, Assistant United States Attorney Southern District of New York 1 Saint Andrews Plaza New York, New York 10007 EFTA00085081