EFTA01656872.pdf

From: (USANYS)" < To: (USANYS)" Cc: "Maxwell, Rita (USANYS)" <Rita.Maxwell@usdoj.gov> Subject: [EXTERNAL EMAIL] - RE: [EXTERNAL] Propose Protocols Date: Sun, 10 Aug 2025 22:11:28 +0000 Importance: Normal That works for me. I'll try to get a draft of a protective order done tonight so we have something to discuss tomorrow that is more appropriate than the draft defense counsel sent us. Assistant United States Attorney United States Attorney's Office Southern District of New York From: Sent: Sunday, August 10, 2025 6:10 PM To: (USANYS C (USANYS) Subject: Re: [EXTERNAL] Propose Protocols Ok. Tomorrow I should be good 10am or later. From (USANYS) Sent: Sunday, August 10, 2025 6:06 PM To: (NY) (FBI) Cc USANYS) >; Grosbard, Remy (USANYS) Su jec : 'AL EMAIL] - RE: [EXTERNAL] Propose Protocols Thanks. Tonight is very tough for me, but may be working. I am around tomorrow morning. From: Thomas Thompson Sent: Sunday, August 10, 2025 6:03 PM To: USANYS)<I IIIIM SANYS) (USANYS) Subject: Re: [EXTERNAL] Propose Protocols Ok. I'm available to talk tonight or tomorrow. From: (USANYS) > Sent: Sunday, August 10, 2025 5:40:44 PM Tomil l(Nar Cc: (USANYS) < (USANYS) Subject: [EXTERNAL EMAIL] - FW: [EXTERNAL] Propose Protocols EFTA01656872 See attached. Putting aside the references to the Philadelphia RCFL, let's discuss at your convenience (over the phone — not email). Thanks, as always, for your help. From: Law Office Of Robert Herz Sent: Sunday, August 10, 2025 3:32 PM To: (USANYS) USANYS) (USANYS) Cc: 'Samuel M. Braverman' ;'Jeff M. u je : roposeProtocols Here is a copy of a Word document with proposed protocols. Mr. Fischbach was in transit to New York yesterday, and we needed some time today for his latest review. Please red-line any of your proposed changes and please use tracking. Jeff will be ready first thing in the morning to access the FBI workstation to secure our defense work product and data. At that point he will be ready to begin work at the Philadelphia RCFL. To allow for expeditious scheduling please inform the RCFL Director that he or his staff is authorized to speak with Mr. Fischbach directly to schedule time in the defense exam room. Thank you. Robert M. Herz Law Offices of Robert Herz, P.C. The Seventh & E Building 431 West Seventh Avenue, Suite 107 Anchorage, Alaska 99501 Denver Place Building 999 18th Street, Suite 300 Denver, Colorado 80202 Email: Web: www.robertherzlaw.com EFTA01656873