From: To: Cc: Subject: RE: United States v. Maxwell, 20 Cr. 330 (AJN) Date: Mon, 27 Jul 2020 22:26:28 +0000 Attachments: GM,_protective_order,_clean_version.docx Attached is a Word version of the proposed protective order we submitted to the Court. In regards to your prior email, it sounds like it would be a more productive discussion after you have had the chance to review the redline of our proposed order. So we propose a call at 9:30am tomorrow morning. Let us know if that works for you and I will circulate a dial-in. Thanks, From: Sent: Monda Jul 27 2020 5:43 PM To: Cc: Subject: RE: United States v. Maxwell, 20 Cr. 330 (MN) MR We also request that the defense provide the Government with a Word version of its proposed protective order submitted to the Court earlier today. We are not able to run a redline using the filed version. Regards, From: Sent: Monday, July 27, 2020 16:43 To: Cc: Subject: RE: United States v. Maxwell, 20 Cr. 330 (AJN) Pursuant to the Court's Order of this afternoon, we write to schedule a telephonic meet and confer on issues relating to a protective order in the above-captioned case. Please let us know what time you are available today between 5:00 p.m. and 8:00 p.m., or tomorrow between 9:00 a.m. and 1:00 p.m. In particular, it would be helpful to get the defendant's current position on the following: - Whether you are aware of any case in any federal district in which a protective order was entered in a criminal case that prevented the Government from showing its own documents to prospective witnesses or their counsel without requiring restrictions upon those witnesses and their counsel; EFTA00020670