Document EFTA 02836221¶
United States Attorney Southern District of New York¶
The Silvio! Mono Building One Saint Andrew’s Plaza New York. New York 10007¶
December 15, 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 (MN)¶
Dear Judge Nathan:¶
The Government respectfully seeks redactions to the defendant’s letter motion seeking testimony of Jack Scarola, Brad M, and Robert Glassman, and the sealing of Exhibit 1 to that letter (Dkt. No. 544). The Government’s proposed redactions are consistent with the threepart test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the letter and exhibit are judicial documents subject to the common law presumption of access, the limited proposed redactions and sealing are narrowly tailored to protect the privacy interests of a Minor Victim who is subject of the Court’s pseudonym order.¶
Respectfully submitted,¶
DAMIAN United States Attorney¶
By: sJ Maurene Convey Alison Moe Lam Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York¶
Cc: Defense Counsel (By ECF)¶