Emails between prosecutors and defense counsel about meeting a witness

Suzanne,¶

We wanted to follow up on our most recent meeting the week before last—as we mentioned then, we think it would be productive and useful to be able to speak with directly, if she is willing to convey any information to us directly, including with any of the protections and/or limitations we previously discussed. Or if you don’t believe that would be productive, please let us know and we can consider possible next steps. Either way, we’re also happy to chat via phone if that would be useful as well.¶

Thanks, Suzanne, we’ll plan on 3:30 then. We have no hard stop that afternoon, so we can meet for as long as you need. Thanks.¶

Yes. We can do that. How much time will you have for our meeting?¶

Suzanne Jaffe Bloom¶

Partner¶

Winston & Strawn LLP¶

200 Park Avenue¶

New York, NY 10166-4193¶

http://www.winston.com¶

-----Original Message-----¶

EFTA00079112¶

Hi Suzanne,¶

Would it be possible to meet at 3:30 instead of 2:30 on October 18th? Thanks, and apologies for all the scheduling difficulties.¶

Thanks,¶

We can do 2:30 p.m. on Friday, October 18. It’s in our calendars for then—thanks.¶

-----Original Message-----¶

EFTA00079113¶

Suzanne,¶

Thanks, and following up, at least three of the five team members will be traveling each of the other days next week that you mentioned, so if it’s at all possible to still do the 10th as originally proposed that would be ideal.¶

Okay. My other commitment would require me to be out of the city all day 10/10. So please do let me know on Monday whether any of the other dates (10/15 - after 2 pm; 10/16 - after 2:30; 10/17 - anytime) would work. If not, I’ll try to move things around to make 10/10 work. Many thanks and safe travels to all!¶

Suzanne Jaffe Bloom¶