EXHIBIT 7

Case 1:20-cv-21254-BB Document 47-8 Entered on FLSD Docket 07/02/2021 Page 1 of 3
Archived: Thursday, July 1, 2021 2:14:23 PM

From: Viswanatha, Veena

Mail received time: Mon, 28 Jun 2021 12:28:25

Sent: Mon, 28 Jun 2021 12:28:24 

To: Petrilla, Antony Braunstein, Joshua

Cc: Regan, Christopher greenbergb@gtlaw.com Rauh, Olivia Turner, Nancy

Subject: RE: SMAIL SEC Response Providing OIG Documents (Email 1 of 3)

Importance: Normal

Sensitivity: None

Tony and Josh,

Thank you for the production of OIG documents on Friday that hit on the search terms “apple” and “convertible.” Can you

advise how many documents hit on each search term? We ask in particular because many of the documents you produced do

not appear to hit on either term. Have all the documents that hit on “apple” and convertible” been produced or do you

expect to make any additional production in response to Judge Louis’s June 22, 2021 Order?

Also, we understand you did not produce any documents that hit on the search terms “trader” or “factors” because the

searches for those terms returned more documents than hit on the terms “apple” or “convertible.” Can you advise how many

documents hit on “trader” and “factors”?

We note that there are many gaps in the bates range you assigned to the documents produced on Friday. Can you advise

whether this was the result of inadvertent error, or whether all of the omitted ranges are documents over which you are

asserting a privilege? If the latter, please advise immediately of the basis of your privilege assertion, especially given Judge

Louis’s questions at the hearing as to how any of the documents in the database—which we understand consists of

communications with third parties—could be privileged. See Order at 3 (“I do not entirely understand the SEC’s proffer as to

why the documents or information would be privileged.”) As you know, we must file a motion by this Friday if we are

seeking additional documents from the OIG database. Accordingly, we ask that you immediately provide the basis of any

privilege assertions. 

Finally, if you have any additional information concerning the SEC’s alleged burden in reviewing and producing the

documents we have requested from the OIG database, we ask that you provide it now so that we may consider any alleged

burden in narrowing the scope of our requests.

Veena

Veena Viswanatha

Buckley LLP

T (202) 461-2947

M (908) 420-0113

vviswanatha@buckleyfirm.com

From: Petrilla, Antony <sec.notification@zixmessagecenter.com> 

Sent: Friday, June 25, 2021 8:45 PM

To: Viswanatha, Veena <vviswanatha@buckleyfirm.com>

Subject: SMAIL SEC Response Providing OIG Documents (Email 1 of 3)

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Case 1:20-cv-21254-BB Document 47-8 Entered on FLSD Docket 07/02/2021 Page 2 of 3
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Case 1:20-cv-21254-BB Document 47-8 Entered on FLSD Docket 07/02/2021 Page 3 of 3