Case 1:13-cr-00452-WFK Document 111 Filed 03/26/14 Page 1 of 3 PageID #: 402

U.S. Department of Justice United States Attorney Eastern District of New York
CAO/SSS F. # 2011R01982
271 Cadman Plaza East Brooklyn, New York 11201

March 26, 2014 By ECF See Distribution List Re: United States v. Sandy Winick, et al., Criminal Docket No. 13-452 (S-1)(WFK)

Dear Counsel: Pursuant to Rule 16 of the Federal Rules of Criminal Procedure, and your executed protective stipulations, the government hereby furnishes the following additional discovery with respect to the above-referenced matter (Discovery 4). This submission, which is composed of two sets, supplements the governments earlier disclosures. With this production, the government renews its request for reciprocal discovery from the defendants. As noted by the prior letters, the production of these consent materials pursuant to protective stipulations has placed the parties ahead of the schedule discussed by the Court at the December 19, 2013 status conference. Discovery 4 - Set 1 spans the following Bates Range: WIN-ADV-FEE037348 WIN-ADV-FEE 366360. This first set, which spans approximately 329,012 pages, contains a Financial Database, linesheets relating to the earlier disclosed court-ordered recordings and the Gmail Emails form the March 3, 2014 production. These emails were originally produced in Discovery 3, but defense counsel said that they would like a format other than the native file. They are now being reproduced in Concordance format. This reproduction constitutes the bulk of the materials in this set. In reproducing the materials in a new format, the government is exceeding the discovery requirements under the Electronically Stored Information (ESI) Protocol. See http://www.fd.org/docs/litigationsupport/final-esi-protocol.pdf. The original bates number for the email disc, in its native format, was WIN-ADV-FEE 037943. Discovery 4 Set 2 includes the following Bates Range: WIN-ADV-FEECON 000001 - WIN-ADV-FEE-CON 000002. These two discs of materials contain consensual wiretaps recordings and consensual wiretap linesheets. By accepting these

Case 1:13-cr-00452-WFK Document 111 Filed 03/26/14 Page 2 of 3 PageID #: 403

materials, you are again indicating your acceptance of the terms of the previously distributed protective stipulation. As shown by the March 12, 2014 discovery letter, Defendant Sahachaisere has already received these consent materials. You may request all or part of the aforementioned materials by contacting Joe Meisner at First Choice Copy, telephone number (718) 381-1480, extension 212, and asking for print job numbers 80060 (Set 1). For Set 2 (the consent wire materials), please contact me for the print order number. Not everyone has executed the stipulation at this time. Only counsel of record or someone from counsels office will be permitted to obtain the materials. Given the size of the production, the government recommends that you request the materials in disc or hard drive format and not in paper format. If you have any questions or further requests, please do not hesitate to contact me. Very truly yours, LORETTA E. LYNCH United States Attorney By: /s/ Christopher Ott Sylvia Shweder Assistant U.S. Attorneys (718) 254-6154/6092

cc:

Clerk of the Court (WFK) (by ECF)

Distribution List: Larry Dubin, Esq. 401 Broadway, Suite 306 New York, NY 10013 Counsel for Gary Kershner Joseph Gentile, Esq. 1527 Franklin Avenue, Suite 104 Mineola, NY 11501 Counsel for Court Poyner 2

Case 1:13-cr-00452-WFK Document 111 Filed 03/26/14 Page 3 of 3 PageID #: 404

Charles Hochbaum, Esq. 16 Court Street, Suite 1800 Brooklyn, NY 11241 Counsel for Gregory Curry Richard Rosenberg, Esq. 217 Broadway, Suite 707 New York, NY 10007 Counsel for Sandy Winick Edward Sapone, Esq. 40 Fulton Street, 23rd Floor New York, NY 10038 Counsel forWilliam Seals Joel Stein Esq. 30 Wall St 8th floor New York, New York 10005 Counsel for Songkram Sahachaisere