Doc 54-1 OCR extract
From: Elizabeth Lowery
Sent: Friday, October 31, 2008 5:23 PM
To: shannon.hanson(@usdoj.gov
Cc: Elizabeth Lowery
Subject: Joseph Mangiapane
Dear Ms. Hanson,
As we agreed during our telephone conversation today, Mr. Mangiapane will voluntarily cooperate and does not need to make arrangements to provide grand jury testimony on November 13, 2008. Instead, he will provide a proffer in California sometime in November or early December, after which time it will be determined whether he will need to travel to Delaware to provide the grand jury testimony in mid-December 2008. As we discussed I will need to attend the informal interview, and I am already scheduled to go to trial on November 20th, 2008. If that matter is not resolved or continued, we will not be available for the informal meeting in Los Angeles until the week of December 1, or 8th, 2008. I should know by the end of next week whether that matter will go forward on November 20th, 2008, and will call yo when I do.
In the meantime, please feel free to contact me when you are ready to make further arrangements. Thank you so much for your continued cooperation,
Elizabeth
From: Elizabeth Lowery
To: Hanson, Shannon (USADE)
Cc: Elizabeth Lowery
Sent: Fri Nov 07 18:27:39 2008
Subject: FW: Joseph Mangiapane
Dear Ms. Hanson:
I am still uncertain whether my November 20th, 2008 trial will be continued. Since next Tuesday is a holiday, I am going to court next Wednesday, November 12th ex-parte to move to postpone that trial, so I will contact you with the result when I return to my office. Also, could you please confirm that Mr. Mangiapane is not a target in your investigation.
Until next week,
Elizabeth
From: Hanson, Shannon (USADE)
[mailto:Shannon.Hanson(ausdoj.gov]
Sent: Saturday, November 08, 2008 4:52 PM
To: Elizabeth Lowery
Subject: Re: Joseph Mangiapane
Ms. Lowery:
Your time table is fine. I know how frustrating it can be not to know whether or not you are going to trial. Mr. Mangiapane is not a target of our investigation. He is a subject.
I will look forward to hearing from you when you know more.
Sincerely,
Shannon
From: Hanson, Shannon (USADE)
[mailto:Shannon.Hanson@usdoj.gov]
Sent: Monday, November 17, 2008 7:40 AM
To: Elizabeth Lowery
Subject: RE: Joseph Mangiapane
Dear Ms. Lowery:
Thanks for the update on your trial date (so glad to hear that!) and the meeting with Mr. Mangiapane. As it stands, it looks as though we are looking at 12/1-12/3 or, possibly, 12/5. If we have to go into the next week, we are looking at 12/8. Please take a look and let me know which of those dates might work for you. (We went ahead and scheduled other matters for this week when we knew that you were up in the air, and next week is not a week anyone would like to travel, I am sure.)
Thanks much. I look forward to hearing from you.
Shannon
From: Elizabeth Lowery
[mailto:ELowery(aedgertonweaver.corn]
Sent: Monday, November 17, 2008 9:42 PM
To: Hanson, Shannon (USADE)
Cc: Elizabeth Lowery
Subject: RE: Joseph Mangiapane
Dear Ms. Hanson,
Mr. Mangiapane and I are available on Wednesday, December 3rd, or Monday, December 8th, 2008. Please let me know which of those two dates works for you. We would also like to know how long you anticipate our meeting will be, as well as the location. Because Mr. Mangiapane is likely to be traveling from down south, we prefer to meet with you in the afternoon if possible.
Thank you for your ongoing cooperation,
Elizabeth
From: Elizabeth Lowery
Sent: Monday, November 17, 2008 10:12 AM
To: Hanson, Shannon (USADE)
Cc: Elizabeth Lowery
Subject: RE: Joseph Mangiapane
Thank you for the dates. I will coordinate my calendar with that of my client and get back to you today or tomorrow,
Elizabeth
From: Elizabeth Lowery
<ELowery@edgertonweaver.com>
To: joemetz98@aol.com
Cc: Elizabeth Lowery <ELowery@edgertonweaver.com>
Sent: Mon, 17 Nov 2008 10:49 am
Subject: FW: Joseph Mangiapane
Hi Joe,
I will most likely be out of town for the Thanksgiving weekend, so I prefer Monday, December 8th, or Wed. Dec. 3, how do those dates work for you? It would be great if they only need you a few hours, if we could plan to meet immediately before. Friday Dec. 5th I am traveling to Tampa for another matter.
Let me know,
Elizabeth