Mr. Ashby,
I write in response to your letter dated January 18, 2023, requesting a second extension of the return date for the next rolling production of documents responsive to Grand Jury Subpoena No. 22-GJ-4481. The government consents to extending the deadline for the second rolling production to **February 10, 2023**. We note that Mr. Caldwell's first rolling production of 1,842 documents (Bates Nos. CALDWELL-00001 through CALDWELL-01842), delivered on January 20, 2023, was timely, and we appreciate his continued cooperation with this process.
This extension is granted with the understanding that the second production will include a substantial portion of the remaining responsive, non-privileged documents, and that any documents beyond the second production will be produced promptly thereafter. We also expect that a privilege log identifying all documents withheld on the basis of any privilege will accompany the final production. The government reserves its right to seek additional documents or testimony as may be necessary following its review of the productions. This accommodation is, of course, contingent upon Mr. Caldwell's continued full cooperation with the subpoena.
Please do not hesitate to contact me 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) 637-1843
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