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From: Goldberg (Legal), Jeffrey Sent: Tuesday, August 20, 2019 AR M. To: Subject: RE: Subpoena CRIM1031692 Hi I have conflicts early and late tomorrow, but perhaps we could speak Thursday morning? Would 10:30am PT (1:30pm ET) on Thursday work for you? Thanks, Jeff From: Sent: Tuesday, August 20, 2019 7:10 AM To: Goldberg (Legal), Jeffrey Cc: Subject: RE: Subpoena CRIM1031692 Jeff, Is there is a good time for a call tomorrow to discuss? I’m tied up between 2 and 5 EST, but otherwise available. Thanks, From: Sent: Thursday, August 15, 2019 2:43 PM To: Goldberg (Legal), Jeffrey 4 ::• Cc: EMES Subject: RE: Subpoena CRIM1031692 Jeff, with apologies for shuttling you back and forth, due to my upcoming trial my colleague copied, will be in a better position to follow up with you. I updated her on our conversation, in particular that you expected to send us some authority for Amazon’s prior position, and also that you were in the process of evaluating whether any First Amendment considerations were still active given the death of Mr. Epstein. I’ve also conveyed to her the issue you raised of the overbreadth of any request for all information for all accounts having ever shipped to, or billed in connection with, the listed addresses, and our interest in at the very least getting account information for any accounts that include those addresses—and, more generally, the records of items shipped to those addresses, to the extent all such records were not included in the first production. Again, sorry to be switching given our lengthy conversation, butMl will better be able to be in touch with you in the coming days. thanks, From: Goldberg (Legal), Jeffrey Sent: Wednesday, August 14, 2019 02:09 To: Subject: Subpoena CRIM1031692 EFTA00079909¶
It was good speaking to you yesterday. Are you available tomorrow (Wednesday) or Thursday for a follow-up call? My schedule is quite tight tomorrow so happy to do it Thursday, if you’d prefer. Thanks, Jeff Jeffrey A. Goldberg Associate General Counsel, Litigation & Regulatory Amazon.com Inc. 2021 7th Avenue, Seattle, WA 98121 <Amazon.com LLC v. Lay, 758 F. Supp. 2d 1154 (W.D. Wash. 2010).pdf> <In re Grand Jury Investigation of Possible Violation of 18 USC § 1461 et seq. (D.D.C. 2009).pdf> <In re Grand Jury Subpoena to Amazon.com Dated August 7, 2006, 246 F.R.D. 570 (W.D. Wis. 2007).pdf> <In re Grand Jury Subpoena to Kramerbooks & Afterwords Inc., No. 98-135 (NHJ) & 98-138 (NHJ) (D.D.C. Apr. 6, 1998).pdf> <Tattered Cover, Inc. v. City of Thornton, 44 P.3d 1044 (2002).pdf> EFTA00079910¶