To: Jeff Pagliuca <q. Brian Burns GB Ce: "ceverdell >, Patrick Smith < gura Menninger (USANYS)" < Subject: RE: Subpoena for Date: Thu, 18 Nov 2021 02:27:03 +0000 Attachments: 2021.11.14 Mtn for Order Auth a Sub Pursnt_to F.R.Crim.P_17(c) (3) re. MB pdf; 2021.11.14 Ex. 1.pdf Inline-Images: image001 .gif; image002.jpg Thanks, Jeff. Brian, in light of Jeff’s email, attached is the unredacted defense motion. Thanks From: Jeff Pagliuca Sent: Wednesday, November 17, 2021 9:07 PM To: Brian Burns Cc: ceverdell |; Patrick Smith < >; Laura Menninger | ee USANYS) <i >; a Subject: [EXTERNAL] Re: Subpoena 1 iii Brian, | believe that we were waiting for any proposed redactions from the government. We have no problem with the government sending you a copy of the motion. If the government does not object, we will send it. However, the government has designated every production confidential, subject to its protective order, and the motion contains information designated as confidential. Accordingly, we will defer to it as to what you should receive. Best Regards, Jeffrey S. Pagliuca. On Nov 17, 2021, at 7:58 PM, Brian Burns Po wrote: Defense counsel — Would you please provide us a copy of your motion seeking the issuance of this subpoena? We haven't seen a copy. Thank you. Brian T. Burns Smith Villazor LLP 250 West 55th Street, 30th Floor New York, New York 10019 Office TE oirect TE vob iT EFTA00040124

--=PAGE_BREAK=--

From: Christian Everdell Sent: Tuesday, November 16, 2021 8:48 PM Brian Burns Laura Menninger BOBBI C a) a: [-—_ (USANYS) <j; ai______iS SS Subject: [EXTERNAL EMAIL] Subpoena Li Counsel — Attached please find the signed subpoena or Please acknowledge receipt. Regards, Christian R Everdell COHEN & GRESSER LLP https:/www.cohengresser.com/privacy-policy. EFTA00040125