Mr. Ashby,
Thank you for your letter of December 7, 2022, requesting an extension of the return date for Grand Jury Subpoena No. 22-GJ-4481, issued November 18, 2022, to Jonathan R. Caldwell.
After reviewing your request, the government is willing to agree to an extension of the return date from December 9, 2022, to January 20, 2023, and to a rolling production schedule as proposed in your letter. This agreement is contingent upon the government's expectation that Mr. Caldwell will be in substantial compliance with the subpoena by January 20, 2023, with the first rolling production made on or before that date. Any subsequent productions should follow on a prompt and regular basis thereafter until the production is complete. Mr. Caldwell's obligation to produce all responsive, non-privileged documents called for by the subpoena remains in full force.
I would ask that you keep my office apprised of the progress of the document collection and review as the work proceeds. Additionally, I want to take this opportunity to remind you that Mr. Caldwell is expected to preserve all documents and electronically stored information within the scope of the subpoena pending completion of the production. We appreciate Mr. Caldwell's stated willingness to cooperate with this investigation.
We will be in touch separately regarding the scheduling of any testimony. Please do not hesitate to contact me at (212) 637-2218 if you have any questions.
Regards,
Miriam T. Goldfarb Assistant United States Attorney Complex Frauds & Cybercrime Unit U.S. Attorney's Office Southern District of New York 500 Pearl Street New York, NY 10007 Tel: (212) 637-2218