📧 Communication

An email chain from August 2, 2019, between Defense Counsel (Garden City, NY) and the US Attorney's Office (SDNY). The discussion concerns the filing of motions related to cell tower data and statements to police. The Defense seeks to file under seal to protect 'cooperating witnesses' and statements, while the Government argues that statements to law enforcement are not 'sensitive' under the protective order. The Government also reprimands the Defense for previously filing sensitive exhibits publicly in error. Additionally, the Defense notes logistical issues with having the defendant sign an affidavit at the MCC without their own team acting as witnesses.