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On Mar 3, 2020, at 6:15 PM,

wrote:

Michael,

Wanted to get back to you, as promised – as we indicated previously, the attorney proffers we’ve received from you haven’t caused us to change our view of Ms. status, and I think you’ve generally addressed the initial and follow-up questions we’ve had. I think from our perspective the next step would be to have a conversation with Ms. directly, and to cover with her the same topics that we’ve addressed with you. Ordinarily we would approach a discussion like that simply by going chronologically, and asking follow-up questions as appropriate along the way, but as I’ve mentioned to you previously, if it would be useful to proceed in a different format, or to focus (or avoid) specific topics in a first meeting, I think we would generally be amenable to that. And of course as we’ve also discussed, any discussion would be completely voluntary—not just the interview overall, but any specific topic or question that she wanted to pass on, or discuss with you in the moment, etc., would be totally up to her. Please let us know what you think? We’re also happy to chat via phone if that would be helpful as well.

thanks,



Michael,

Received, thank you. This information is helpful, and as with the prior attorney proffer, does not cause us to change our view of Ms. status.

We will be traveling most of this upcoming week, but I hope that we will be able to follow up with you the following week to discuss possible next steps.

thank you,

From: Michael Bachner

**Sent:** Friday, February 21, 2020 10:45

To:

Subject: RE:



Attorney Proffer



pls see attached replies to your questions.

From: Michael Bachnel

**Sent:** Tuesday, February 18, 2020 12:01

To: