From: Laura Menninger
To: "
[email protected]
Cc:
(USANYS)"
Jeff Pagliuca
Bobbi Stemhenn
Nicole Simmons
Subject: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial]
Date: Thu, 22 Apr 2021 15:22:17 +0000
Attachments: 2021.04.22_Deils_Letter for Adjournment.pdf
Judge Nathan -
Pursuant to this Court's Order of April 20, 2021 (Dkt. 221), attached please find counsel's Letter Motion for an
Adjournment of the trial.
Counsel for Ms. Maxwell request redaction of their other clients' names and case numbers from this Letter Motion
pursuant to Rule of Professional Conduct 1.6 which prohibits lawyers from revealing confidential information related to a
client even where that information is publicly available. See In Re. Anonymous, 654 N.E. 2.d. 1128 (Ind. 1995) (lawyer
violated Rule 1.6 by disclosing information relating to representation of client, even though information "was readily
available from public sources and not confidential in nature"); In re Bryan, 61 P.3d 641 (Kan. 2003) (lawyer violated Rule
1.6 by disclosing, in court documents, existence of defamation suit against former client); State ex rel. Okla. Bar Ass'n v.
McGee, 48 P.3d 787, 791 (Okla. 2002) (a lawyer's duty of confidentiality attaches "to all information relating to the
representation, whatever its source").
Upon direction of the Court, counsel will file either the redacted or unredacted version of this letter on the public docket.
Best regards,
Laura Menninger
Laura A. Menninger I Partner
Haddon, Mor an & Foreman, P.C.
O 80203
EFTA00039816