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Case 2:18-cr-00422-DJH Document 1018-2 Filed 06/12/20 Page 1 of 4
From: Bruce Feder

To: Elaine Garcia; Perlmeter, Margaret (USAAZ); Kozinets, Peter (USAAZ); Kucera, John (USACAC); Rapp, Kevin

(USAAZ); Stone, Andrew (USAAZ); pcambria_lglaw.com; tbienert@bienertkatzman.com; Gary S. Lincenberg;

joy.bertrand_gmail.com; david_deisenbergplc.com; wbernstein@bienertkatzman.com; Erin McCampbell Paris; Ariel

A. Neuman; Gopi K. Panchapakesan

Cc: Feder Law

Subject: Re: USA v. Lacey, etal, , re: DOC 978

Date: Wednesday, June 03, 2020 11:47:44 AM

Attachments: image001.png

Ms Garcia,

 The Bird Marella firm would schedule and host a ZOOM meeting on the date/time of the

hearing that can accomodate >100 participants. It is also my understanding the Court may have 

access to a conferencing program called Cisco Meeting Service that sounds like it is a

comparable system able to accomodate a similar number of participants. It is further my

understanding that these programs allow participants who do not have access to a computer to

also call in to the meeting by phone and participate in that fashion. Please let me know if there

are other questions and/or concerns. Thanks for your quick response.

Bruce Feder

2930 East Camelback Road, Suite 160

Phoenix, Arizona 85016

(602) 257-0135

bf@federlawpa.com

Confidentiality Notice

This email or fax, including attachments, is covered by the Electronic Communications Privacy Act, 18 U.S.C. 1510 et seq. The information

contained in this electronic mail or fax transmission, including any accompanying attachment, is intended solely for its authorized recipient,

and may be confidential and/or legally privileged. If you are not an intended recipient, or responsible for delivering some or all of this

transmission to an intended recipient, you have received this transmission in error and are hereby notified that you are strictly prohibited

from reading, copying, printing, distributing, or disclosing any of the information contained in it. In that event, please contact me

immediately by telephone at (602) 257-0135 or by electronic email at bf@federlawpa.com and delete the original and all copies of this

transmission, including any attachments, without reading or saving them in any manner.

From: Elaine Garcia <Elaine_Garcia@azd.uscourts.gov>

Sent: Wednesday, June 3, 2020 10:37 AM

To: Bruce Feder <bf@federlawpa.com>; Perlmeter, Margaret (USAAZ)

<Margaret.Perlmeter@usdoj.gov>; Kozinets, Peter (USAAZ) <Peter.Kozinets@usdoj.gov>; Kucera, John

(USACAC) <John.Kucera@usdoj.gov>; Rapp, Kevin (USAAZ) <Kevin.Rapp@usdoj.gov>; Stone, Andrew

(USAAZ) <Andrew.Stone@usdoj.gov>; pcambria_lglaw.com <pcambria@lglaw.com>;

tbienert@bienertkatzman.com <tbienert@bienertkatzman.com>; Gary S. Lincenberg

<glincenberg@birdmarella.com>; joy.bertrand_gmail.com <joy.bertrand@gmail.com>;

david_deisenbergplc.com <david@deisenbergplc.com>; wbernstein@bienertkatzman.com

<wbernstein@bienertkatzman.com>; Erin McCampbell Paris <eparis@lglaw.com>; Ariel A. Neuman

<aneuman@birdmarella.com>; Gopi K. Panchapakesan <gpanchapakesan@birdmarella.com>

Cc: Feder Law <fl@federlawpa.com>

Subject: RE: USA v. Lacey, etal, , re: DOC 978

Case 2:18-cr-00422-DJH Document 1018-2 Filed 06/12/20 Page 2 of 4
Mr. Feder, 

Judge Brnovich previously denied the request at Doc. 978 because our VTC

courtrooms cannot handle the high number of participants. Please advise how you

plan to set up the ZOOM. Our office would then need to advise our IT Department to

make sure it is secure to do so. 

Thank you

05/26/2020 view978 ORDER as to James Larkin (2), et al: The Court has considered the

parties request to appear by video conference for oral argument,

scheduled for June 19, 2020. After consultation with Court staff, video

conferencing is not feasible. Therefore, IT IS ORDERED denying the

Motion for Leave to Appear Via Remote Video Teleconference (Doc.

970 ). However, the parties may appear telephonically. The parties

will receive dial-in instructions for connecting to the teleconference

via electronic mail prior to the hearing. ORDERED by Judge Susan M.

Brnovich on 5/26/2020. This is a TEXT ENTRY ONLY. There is no PDF

document associated with this entry. (ESG) (Entered: 05/26/2020)

From: Bruce Feder <bf@federlawpa.com> 

Sent: Tuesday, June 2, 2020 6:55 PM

To: Elaine Garcia <Elaine_Garcia@azd.uscourts.gov>; Perlmeter, Margaret (USAAZ)

<Margaret.Perlmeter@usdoj.gov>; Kozinets, Peter (USAAZ) <Peter.Kozinets@usdoj.gov>; Kucera, John

(USACAC) <John.Kucera@usdoj.gov>; Rapp, Kevin (USAAZ) <Kevin.Rapp@usdoj.gov>; Stone, Andrew

(USAAZ) <Andrew.Stone@usdoj.gov>; pcambria_lglaw.com <pcambria@lglaw.com>;

tbienert@bienertkatzman.com; Gary S. Lincenberg <glincenberg@birdmarella.com>;

joy.bertrand_gmail.com <joy.bertrand@gmail.com>; david_deisenbergplc.com

<david@deisenbergplc.com>; wbernstein@bienertkatzman.com; Erin McCampbell Paris

<eparis@lglaw.com>; Ariel A. Neuman <aneuman@birdmarella.com>; Gopi K. Panchapakesan

<gpanchapakesan@birdmarella.com>

Cc: Feder Law <fl@federlawpa.com>

Subject: USA v. Lacey, etal, , re: DOC 978

Ms Garcia,

 The Court has ordered that counsel may participate telephonically in the 6/19/2020 hearing.

Case 2:18-cr-00422-DJH Document 1018-2 Filed 06/12/20 Page 3 of 4
All defense counsel(and the defendants) request participation in the hearing on an equal basis

with members of the prosecution who may attend in person, but without exposure to the risks

discussed in the recently filed motion seeking a trial continuance. The defense suggests the

option of re-scheduling the hearing to facilitate the use of a ' VTC ' courtroom if that could

accomodate all participants, or alternatively, allowing the defense or prosecution to schedule a

meeting on ZOOM, TEAM or other conferencing product to host the hearing. Please let us

know if this request needs to be filed as a formal motion. Thanks.

Bruce Feder

2930 East Camelback Road, Suite 160

Phoenix, Arizona 85016

(602) 257-0135

bf@federlawpa.com

Confidentiality Notice

This email or fax, including attachments, is covered by the Electronic Communications Privacy Act, 18 U.S.C. 1510 et seq. The information

contained in this electronic mail or fax transmission, including any accompanying attachment, is intended solely for its authorized recipient,

and may be confidential and/or legally privileged. If you are not an intended recipient, or responsible for delivering some or all of this

transmission to an intended recipient, you have received this transmission in error and are hereby notified that you are strictly prohibited

from reading, copying, printing, distributing, or disclosing any of the information contained in it. In that event, please contact me

immediately by telephone at (602) 257-0135 or by electronic email at bf@federlawpa.com and delete the original and all copies of this

transmission, including any attachments, without reading or saving them in any manner.

Case 2:18-cr-00422-DJH Document 1018-2 Filed 06/12/20 Page 4 of 4