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Haddon, Morgan and Foreman, P.C.
Jeffrey Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
www.hmflaw.com
jpagliuca@hmflaw.com
August 24, 2020
VIA EMAIL
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: Proposed Redactions to Request to Modify Protective Order (Under Seal)
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
In accordance with this Court's Order of August 18, 2020 (Doc. 44), Ms. Maxwell hereby respectfully submits under seal her proposed redactions to her Request to Modify Protective Order ("Request"), filed under seal on August 17, 2020. Ms. Maxwell also has filed her Reply under seal and contemporaneously submits her proposed redactions to that pleading.1
Ms. Maxwell has no opposition to keeping under seal, and redacting from her Request and Reply, the contents, description and discussion of the sealed materials themselves; because the government has marked them Confidential, the Protective Order requires as much. See Doc. 36, ¶ 15.
The government's proposed redactions, however, go further and propose to redact . The government would have this Court redact on the premise that it would "risk jeopardizing the government's investigation."
1 To the extent this Court believes this letter also should be filed publicly, counsel also has indicated her proposed redactions to this letter.
App.112
DOJ-OGR-00019571