Thanks so much for putting this spreadsheet. I’m attaching an updated version, which incorporates everyone’s edits, so this version is ready to go. As you’re prepping the production, please let us know if you have any questions. Two notes:¶
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There are a number of folders marked “not a witness.” Could you please move all of those folders into one place and send us a link to that group? We are going to review those materials and likely produce all or most of the documents, but outside the context of 3500, for a variety of reasons.
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As a heads up, we have a call scheduled with our case agents next week to discuss any e-communications they may have had with witnesses. We’ll talk to them about the process of gathering those materials. Down the road, we’ll connect them with you to hand off those materials to add to our 3500 productions, but we wanted to let you know in advance about this additional universe of disclosures.
Thanks very much,¶
I’ve taken a stab at filling this in on the attached. would you please double check this and make any changes you think are appropriate?¶
EFTA00088739¶
As discussed, attached is the witness tracking spreadsheet with a column to designate whether someone is a witness/ type of witness. I’ve also saved it on the shared here:¶
| Paralegal Specialist |
| United States Attorney's Office | SDNY |
| 1 St. Andrew's Plaza |
| New York, NY 10007 |
EFTA00088740¶