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Court filing · May 21, 2021

Maxwell defense reply to government on sealing of exhibits, May 21, 2021

Document EFTA 02832085

HADDON AN

May 21, 2021

VIA ECF

The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007

Haddon. and MI P.c Jeffrey S. Pagliuca

150 East 10th Avenue Denver. Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmllaw.com jpagiuco4hmflaw.com

Re: Reply to Government Letter dated May 14 Regarding Proposed Redactions to 12, 2021 Letter (DE 283), United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)

Dear Judge Nathan,

On May 14, 2021, the government requested that Exhibits A and 12, 2021 Letter Response to the Government’s Letters dated May 4, and May 6, 2021 regarding F.R. Crim. P. 17(c) subpoena remain sealed. Ms. Maxwell respectfully disagrees, for the following reasons:

Exhibit A, a journal entry, was produced to Ms. Maxwell by Accuser-2 in civil discovery. The document production was not subject to any protective order and this exhibit was not produced to Ms. Maxwell by the government. As detailed in Ms. Maxwell’s Response to the Government’s Letters dated May 4, and May 6, 2021 regarding F.R. Crim. P. 17(c) subpoena, Accuser-2 has publicly discussed her journal, generally, and this entry specifically. Exhibit B appears to be a different copy of Exhibit A.

The government has offered no reason why either Exhibit should remain sealed. The Exhibits are “judicial documents” presumptively subject to the public access rights under both

May 21, 2021

Page 2

the common law and First Amendment. Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110,

119 (2d Cir. 2006); v. Maxwell, 929 F.3d 41, 49 (2d Cir. 2019). Ms. Maxwell also

specifically asserts her right to an open and public trial pursuant to the Sixth Amendment. Press-

Enterprise Co. v. Superior Court (Press-Enterprise II), 478 U.S. I, 7 (1986).

Respectfully Submitted,

Jeffrey S. Pagliuca

CC: Counsel of Record (via ECF)

Maxwell defense reply to government on sealing of exhibits, May 21, 2021

Court filings

Court Records: United States v. Maxwell (S.D.N.Y. 1:20-cr-00330) · May 21, 2021

Document EFTA 02832085 HADDON AN May 21, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Haddon. and MI P.c Jeffrey S. Pagliuca 150 East 10th Avenue Denver. Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmllaw.com jpagiuco4hmflaw.com Re: Reply to Government Letter dated May 14 Regarding Proposed Redactions to 12, 2021 Letter (DE 283), United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, On May 14, 2021, the government requested that Exhibits A and 12, 2021 Letter Response to the Go…