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HADDON MORGAN FOREMAN August 17, 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: Request to Modify Protective Order (UNDER SEAL) United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, Defendant Ghislaine Maxwell, pursuant to paragraph 18 of this Court's Protective Order (Doc. # 36), requests that the Court enter an Order allowing her to refer to and file under seal in (the "Other Matters"), certain discovery materials produced by the government on August 5, 2020. She also seeks to refer to (but not file) discovery materials produced by the government on August 13, 2020, specifically . Disclosure to the judicial officers in the Other Matters is necessary for fair determination of important issues . 1 Ms. Maxwell seeks leave to file this Letter Motion under seal because it relates and refers to discovery materials deemed Confidential under the terms of the Protective Order in this case. 2 App.104 DOJ-OGR-00019563