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Case 1:13-cr-00452-WFK Document 72 Filed 11/12/13 Page 1 of 2 PageID #: 251

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

November 12, 2013 By ECF and email Attached Counsel 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, the government hereby furnishes the following additional discovery with respect to the abovereferenced matter. This submission supplements the governments earlier disclosures. The government also renews its request for reciprocal discovery from the defendants. You may request copies of two discs, containing: (1) the line sheets, applications and orders of the previously supplied telephone call recordings from the seven court-authorized wiretaps relating to the defendants conspiracies. The line sheets are Bates numbered WINADV-FEE 009463 010499. The applications and orders are Bates numbered WIN-ADV-FEE 010500 011318; and (2) additional documents from the financial database, Bates numbered WINADV-FEE 011319 017914. You may request the aforementioned discs by contacting Joe Meisner at First Choice Copy, telephone number (718) 381-1480, extension 212, and asking for print job number 80052. Only counsel of record or someone from counsels office will be permitted to obtain the discs. The government recommends that you request the discs in disc format and not in paper format. Please call me to arrange a mutually convenient time to inspect, copy and/or photograph the evidence and original documents discoverable under Rule 16.

Case 1:13-cr-00452-WFK Document 72 Filed 11/12/13 Page 2 of 2 PageID #: 252

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


Clerk of the Court (WFK) (by ECF)

Defense counsel: 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 Cort Poyner 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 Lawrence Ruggiero, Esq. 167 East 61st Street, Suite 17E New York, NY 10065 Counsel for Joseph Manfredonia Edward Sapone, Esq. 40 Fulton Street, 23rd Floor New York, NY 10038 Counsel for William Seals Joel Stein, Esq. 186 Joralemon Street #9 Brooklyn, NY 11201 Counsel for Songkram Sahachaisere