BUTZEL LONG ATTORNEYS AND COUNSELORS a professional corporation George B. Donnini 313 225 7042 donnini@butzel.com Suite 100 150 West Jefferson Detroit, Michigan 48226 butzel.com Also Admitted in California and New York February 21, 2020 Assistant United States Attorney Southern District of New York One St. Andrew's Plaza New York, New York 10007 Esq. Re: Interlochen Center for the Arts Grand Jury Subpoenas dated February 6 &10, 2020 As you know, I represent Interlochen Center for the Arts (“Interlochen”) in connection with its response to the two subpoenas issued by your office. Enclosed please find executed custodian certifications along with a confidential document production on behalf of Interlochen in response to the subpoenas duces tecum that was served by your office on the custodian of records for Interlochen. The enclosed flash drive includes those responsive documents with a bates range as follows: - INT000001 – INT000293 responsive to February 6, 2020 Subpoena; and - INT000294 – INT000631 responsive to February 10, 2020 Subpoena. The files are encrypted and the password will be sent to you via email. Consistent with our prior communications, Interlochen is committed to cooperating fully with your office. The submission of this letter and the materials enclosed herewith is without prejudice to, and with full reservation of, all privileges, rights, and protections. Interlochen requests that this letter and the materials attached hereto be treated as exempt from disclosure, under the Freedom of Information Act, 5 U.S.C. § 552 (“FOIA”), and as confidential pursuant to 28 C.F.R. § 16.8.
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EFTA00088556 We submit these materials to you with the understanding that your office's request for this information is relevant and materials to a valid law enforcement purpose. We further submit these materials to you with the understanding that they will remain confidential unless and until they are made public by the Court. Finally, we submit these materials to you with the understanding that, in the event that any privileged or work-product protected documents are produced, inadvertent or otherwise, your office will promptly destroy each copy of any such document that is in the possession, custody, or control of the United States. See, e.g., Fed. R. Civ. P. 26(b)(5)(B). If you have any questions or concerns, please do not hesitate to contact me. Very truly yours, George B. Donnini