Document EFTA 02831961¶
United States Attorney Southern District of New York¶
The Silvio J. Mello Building One Saint Andrew’s Plaza Neu• York New• York 10007¶
May 12, 2021¶
BY ECF¶
The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007¶
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)¶
Dear Judge Nathan:¶
The Government respectfully submits this letter in response to the Court’s Order dated May 10, 2021, which directed the Government to propose and justify any requests for redaction of the defendant’s memorandum in support of her supplemental pm-trial motions and exhibits. (Dkt. No. 274).¶
After reviewing the defense’s memorandum, the Government seeks a limited number of redactions. These proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the defense’s memorandum in support of her supplemental pm-trial motions is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims and third parties referenced in the document. These redactions are thus consistent with similar, tailored redactions permitted by the Court in this case to protect the privacy interests of third parties. (See. e.g., Dkt. No. 168, 232). Today the Government is submitting to the Court by email its proposed redactions to the defense’s memorandum, which the Government respectfully requests be filed under seal.¶
The Government respectfully submits that Exhibits C, E, F, G, 14, and I should be filed entirely under seal in order to protect the privacy interests of victims and third parties implicated in the documents. The Court has accepted similar exhibits under seal in this case to protect such privacy interests. (See, e.g., Dkt. No. 168, 232).¶
Respectfully submitted,¶
AUDREY STRAUSS United States Attorney¶
By: s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York¶
Cc: Defense counsel (By ECF)¶