EFTA00021746

On Aug 2, 2019, at 12:10 PM, (USANYS) < wrote: We had the court seal the documents, and per the Court's request, are following up with a formal letter request to do so. We do not believe there is a legitimate legal basis to seal statements, but if you can point us to any authority, we are happy to look at it. Assistant United States Attorney

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(USANYS) imailto: ( As you know, the protective order distinguishes between all discovery and that marked "sensitive," and it is the sensitive discovery that cannot be publicly filed. statements to law enforcement do not fall into the sensitive category, so they should be publicly filed. We'd ask that, consistent with the protective order, any sensitive discovery and references to cooperators be redacted in your public filings. Along the same lines, we noticed that you publicly filed four documents that were marked sensitive (Exhibits A through D to your cell site motion) in violation of the protective

order. We will be asking the Court to remove them from the docket and you will need to refile.

Assistant United States Attorney

It is a little difficult to know what needs to be sealed/redacted in the abstract. Out of an abundance of caution, can you file the documents with any reference to evidence/discovery and cooperators redacted? We can then review the unredacted version and discuss what, if anything, can be unredacted for the public version. Assistant United States Attorney