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E-FILED

Wednesday, 07 October, 2015 01:58:29 PM

Clerk, U.S. District Court, ILCD
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF ILLINOIS
IN RE SPRINGFIELD GRAND JURY
INVESTIGATION.

Case No. 15-mc-3005

AARON SCHOCK OPPOSITION TO GOVERNMENTS MOTION FOR LEAVE TO

FILE SUPPLEMENTAL REPLY TO NOTICE OF COMPLIANCE WITH SUBPOENA
Aaron Schock, through counsel, respectfully files this opposition to the Governments
motion for leave to file a supplemental response to Mr. Schocks Notice of Compliance with
Subpoena. The United States Attorneys Office (USAO) has already filed a Response to the
Notice of Compliance, d/e 84, a Supplemental Response to the Notice of Compliance, d/e 88,
and has now filed a 10-page motion containing pages of argument, requesting to file yet another
supplemental response, d/e 95.
Assuming this motion is a preview of the filing to come, the USAO should not be
permitted to file yet another supplemental response, as the motion is replete with omissions,
erroneous assertions, and unsubstantiated accusations.1 If this Court does permit a second
supplemental response, Mr. Schock requests the opportunity to reply to correct these errors and
omissions.

As but one particularly egregious example, the USAO baselessly insinuates that the reason Mr. Schock withdrew
his assertion of privilege as to three documents was because the government has requested documents from third
parties identified in the privilege log. As this Court is aware from Mr. Schocks ex parte filing, the privilege claim
was withdrawn for a technical legal reason, not because of any attempt by the USAO to obtain documents
elsewhere. Moreover, as the USAO is well aware, there are 11 other documents involving the same third party for
which Mr. Schock is still maintaining privilege. Thus, it defies logic for the USAO to claim that Mr. Schock has
withdrawn his privilege claim on three documents involving a particular third party from whom the USAO has said
it is seeking documents but not the other 11 involving that same third party.

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We respectfully submit, however, that additional briefing is unnecessary for the Court to
conduct its in camera review of the documents provided by Mr. Schock.

Dated: October 7, 2015

Respectfully submitted,

/s/ Christina M. Egan

_____________________________
Christina M. Egan
MCGUIREWOODS LLP
77 West Wacker Drive
Suite 4100
Chicago, IL 60601-1818
Tel: 312.750.8644
Fax: 312.698.4502
Email: cegan@mcguirewoods.com

/s/ George J. Terwilliger III

_____________________________
George J. Terwilliger III
MCGUIREWOODS LLP
2001 K Street N.W., Suite 400
Washington, D.C. 20006-1040
Tel: 202.857.2473
Fax: 202.828.2965
Email: gterwilliger@mcguirewoods.com

/s/ Jeffrey B. Lang

___________________________
Jeffrey B. Lang
LANE & WATERMAN LLP
220 N. Main Street, Suite 600
Davenport, Iowa 52801-1987
Tel: 563.333.6647
Fax: 563.324.1616
Email: jlang@L-WLaw.com

Counsel for Aaron J. Schock

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CERTIFICATE OF SERVICE
The undersigned certifies that the foregoing instrument was electronically filed with the
Clerk of the Court using the CM/ECF system, which will send notification of such filing to
counsel of record at their respective email addresses disclosed on the pleadings on this 7th day of
October 2015.

/s/ Jeffrey B. Lang

_____________________
Jeffrey B. Lang