# Document EFTA 02831970



United States Attorney Southern District of New York

The Silviol Mono Building One Saint Andmr's Plaza New York. New York 10007

May 14, 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 13, 2021, which directed the Government to propose and justify any requests for redaction of the defendant's response to the Government's letters of May 4 and May 6, 2021 and the attached exhibits. (Dkt. No. 279).

After reviewing the defense's letter and exhibits, the Government respectfully submits that Exhibits A and B should be filed under seal. This proposal is 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 letter and exhibits are judicial documents subject to the common law presumption of access, sealing the exhibits—each of which is only one page—is narrowly tailored to protect the privacy interests of a victim and third party implicated in the documents. The Court has accepted other exhibits under seal or in redacted form 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 Lam Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York

Cc: Defense counsel (By ECF)