Case ECF No. 322 filed 10/04/18 PagelD.13478 Page 1 of 5 LAW OFFICES OF BEN M. GONEK 500 Griswold Street, Suite 2450 Detroit, Michigan 48226 Telephone: (313) 963-3377 Facsimile: (313) 963-9310 Ben M. Goneit October 4, 2018 Honorable Anthony P. Patti, United States Magistrate Judge Theodore Levin United States Courthouse 231 Lafayette Boulevard, Room 524 Detroit, Michigan 48226 Re: State Farm v. Elite Health Centers. et al., 16-cv-13040 Request for Leave to File Motion for Protective Order Dear Judge Patti: Jayson Rosett seeks leave to ?le a motion for a protective order. Mr. Joelson, counsel for some of the other defendants has noticed up Mr. Ro'sett?s deposition for October 26, 2018. I requested that any deposition of Mr. Rosett be scheduled for at least 90 days from now. Mr. Joelson declined my request. The protective order we are seeking would preclude Jayson Rosett?s deposition from being taken for at least 60 days. Mr. Rosett is currently the target of two federal investigations that involve conduct directly related to some of the allegations State Farm has made in this case. (See attached target letters from the respective Assistant United States Attorneys handling the respective investigations). Mr. Rosett expects to be charged in at least one case in early November 2018. We are in negotiations with the Government for resolutions in both cases and expect to have some type of resolution in both cases within the next 60 days. At that time, Mr. Rosett will be in a better position to make an informed decision as to whether or not he wants to exercise his Fifth Amendment rights if deposed. Under existing case law, Mr. Rosett could ask the Court to grant a complete stay of proceedings while his criminal case is pending. However, we do not believe that a stay or proceedings is necessary at this juncture and simply want to facilitate this case moving along in a productive manner. Case ECF No. 322 filed 10/04/18 PagelD.13479 Page 2 of 5 Thank you- for your consideration. Very truly yours. Mk Ben M. Gonek 3' .?zga?s? Case ECF No. 322 filed 10/04/18 PagelD.13481 Page 4 of 5 U.S. Department of Justice United States Attomcy's Office Eastern District of Michigan JULES M. 210 Federal Building Assistant United States Attorney 600 Church Street Flint. Michigan 48502 Telephone: (810) 766-5177 Facsimile: (RIO) 766-5427 E-Mail: Jules.DePorrc@usdoj.gov CONFIDENTIAL May l7. 20w Jayson Rosett Gonck 500 Griswold St. Ste 2450. Detroit, MI 48226-342l Dear Mr. Rosett: Please be advised that you are a target of a criminal investigation which is being conducted by the Federal Bureau of Investigation and a federal grand jury. Before proceeding with this prosecution. I am offering you the opportunity to meet with me and the investigating agents to discuss the investigation. This meeting would have two purposes: 1 for you to provide any reasons why you should not be prosecuted: and 2) to discuss the possibility of a plea bargain. if appropriate. It would be in your best interest to retain a lawyer to represent you at this meeting. I understand that Mr. Gonek has previously represented you. lf such a meeting is beyond the scope of his representation and if you cannot afford to hire a lawyer. please submit this letter to the Federal Defender Of?ce. II E. Court Street. Suite L-l00. Flint. MI 48502. and request that an attorney be appointed for you at the government?s Please contact me by May 20 8 to advise if you are interested in having such a meeting or to advise if you have requested court-appointed counsel. If you or your attorney does not contact me by that date. I will assume that you are not interested in meeting to discuss this case. and I will proceed with this prosecution. Sincerely. MATTHEW SCHNEIDER United States Att ey Jules M. DcPorrc Assistant United States Attorney Case ECF No. 322 filed 10/04/18 PageID.13482 Page 5 of 5 U.S. Department of Justice Tax Division Northem Cn?minal Enforcement Section P. O. Box 972, Ben Franklin Station (202) 514-5150 Washington, D. C. 20044 Telefax: (202)514-8455 October 3, 2018 Jayson Rosett clo Ben Gonek Defense Counsel 500 Griswold, Suite 2450 Detroit. MI 48226 Re: Grand Jury Investigation Dear Mr. Rosett: We write to inform you that you are a target of a federal grand jury?s investigation in the Eastern District of Michigan. The Department of Justice possesses substantial evidence that, among other things, you participated in a scheme to engage in money laundering, in violation of 18 U.S.C. 1956(h) and conspired to defraud an agency of the United States, speci?cally the Internal Revenue Service, in violation of 18 U.S.C. 371. Please have your attorney contact Mark McDonald at (202) 305-2672 to discuss this matter further. Sincerely. Isl Mark McDonald Mark McDonald VWIliam Guappone Trial Attorney