From: To: Subject: KE: 4172 Tetter Date: Fri, 15 Oct 2021 00:58:39 +0000 Attachments: 2021-10-15 Gov't letter re FRE 412 vif ccs Draft back to you. I’m reading Smith now. Very rough draft attached, saved on shared. Take a look at the Smith case/let me know if you find other caselaw? Feel free to edit freely. I'll be back online in a bit but wanted to send something your way. Thanks a Assistant United States Attorney United States Attorney's Office Southern District of New York One St. Andrew’s Plaza New York, New York 10007 EFTA00076467