Exhibit A 

Case 2:18-cr-00422-DJH Document 1062-1 Filed 10/05/20 Page 1 of 3
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Hernandez, Norma (USAAZ)

From: Rapp, Kevin (USAAZ)

Sent: Friday, September 18, 2020 11:47 AM

To: Perlmeter, Margaret (USAAZ)

Subject: Fwd: US v. Lacey et al., 18-cr-00422-SMB

FYI 

Sent from my iPhone 

Begin forwarded message: 

From: Whitney Bernstein 

Date: September 18, 2020 at 10:33:19 AM MST 

To: "Rapp, Kevin (USAAZ)" 

Cc: "Thomas H. Bienert" 

Subject: RE:  US v. Lacey et al., 18‐cr‐00422‐SMB

Hi Kevin, 

  

Thank you for your email.  I will be filing this motion next week, so please let me know if there is a 

definitive government position to represent by then.  Otherwise, will represent the government’s 

position below. 

  

Thank you and have a nice weekend, 

  

Whitney 

  

  

Whitney Z. Bernstein

Attorney | Orange County

Bienert | Katzman PC

Website | vCard | Profile

  

From: Rapp, Kevin (USAAZ)    

Sent: Tuesday, September 15, 2020 3:04 PM 

To: Whitney Bernstein 

Cc: Thomas H. Bienert 

Subject: RE: US v. Lacey et al., 18‐cr‐00422‐SMB 

  

Whitney: 

  

Hope all is well. The team discussed your pending MTC trial. There is not an opposition to the 

continuance but candidly much of it has to do with the combination of you being unavailable for medical 

issues and the unknown status of COVID restrictions. I’m sure you can understand that we are anxious 

to get this case to trial and have concerns that due to the number of attorneys, anyone could have a 

medical issue that would precipitate additional continuances. We do have a requirement to contact the 

victims and seek input.  If you recall, our previous oppositions included input from victims or their 

Case 2:18-cr-00422-DJH Document 1062-1 Filed 10/05/20 Page 2 of 3
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representatives. This will likely take several days.  At this point we would ask that you simply state the 

government is seeking victim input before providing a position. There was a strong consensus, however, 

that our response would be brief.  

  

Best, 

  

Kevin 

From: Whitney Bernstein    

Sent: Monday, September 14, 2020 1:51 PM 

To: Rapp, Kevin (USAAZ) 

Cc: Thomas H. Bienert 

Subject: US v. Lacey et al., 18‐cr‐00422‐SMB 

  

Hi Kevin, 

  

Following up to our call last week,  and accordingly plan to file a motion to 

continue the trial date by four months (from January 12, 2020 to April 12, 2020) to account for my 

pregnancy/disability and maternity leave.  Please let me know the government’s position so we can 

include that in this motion. 

  

Thank you, 

  

Whitney 

  

  

Whitney Z. Bernstein

Attorney | Orange County

Bienert | Katzman PC

Website | vCard | Profile

Los Angeles | 601 W. 5th Street, Suite 720 | Los Angeles, CA 90071 | (213) 528-3400

Orange County | 903 Calle Amanecer, Suite 350 | San Clemente, CA 92673 | (949) 369-3700

The foregoing message is confidential and intended for the designated recipient only. The foregoing information may be protected 

by attorney-client and/or work product privileges. Accordingly, if you have received this message in error, please contact 

BIENERT | KATZMAN PC immediately, and delete the message without reviewing, copying, or making further use of the 

information contained herein.

  

  

Case 2:18-cr-00422-DJH Document 1062-1 Filed 10/05/20 Page 3 of 3