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Document 245

AI Analysis

Summary: The letter is from Laura A. Menninger, counsel for Ghislaine Maxwell, to Judge Alison J. Nathan, discussing proposed redactions to pleadings related to a Rule 17(c) subpoena. The redactions are sought to protect the privacy of a third-party witness mentioned in documents marked 'Confidential' by the government. BSF takes no position on the necessity of the proposed redactions.
Significance: This document is potentially important as it reveals the discussion around redactions to pleadings related to a Rule 17(c) subpoena in the Ghislaine Maxwell case, highlighting the balance between the defendant's rights and the privacy rights of third-party witnesses.
Key Topics: Redactions to pleadings Rule 17(c) subpoena Protective Order and confidentiality
Key People:
  • Laura A. Menninger - Counsel for Ghislaine Maxwell
  • Alison J. Nathan - United States District Court Judge
  • Ghislaine Maxwell - Defendant
  • Ms. McCawley - Counsel from Boies Schiller & Flexner (BSF)
Document Type
Letter
Date
April 19, 2021
Pages
2
Folder
IMAGES002

Full Text

Case 1:20-cr-00330-PAE Document 245 Filed 04/23/21 Page 1 of 2 Haddon, Morgan and Foreman, P.C Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com LMenninger@hmflaw.com April 19, 2021 The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 500 Pearl Street New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Redactions to Pleadings Re: Rule 17 Subpoenas Dear Judge Nathan: Counsel for Ms. Maxwell has conferred with Boies Schiller & Flexner (BSF) concerning any proposed redactions to the pleadings addressing the Rule 17(c) subpoena sub judice, specifically Defendant's Response of April 2 and BSF's Reply of April 5, both of which were submitted to the Court via email in order to allow an opportunity to address any necessary redactions. Ms. Maxwell is mindful of the Court's previous directive that any proposed redactions must be specifically justified and tailored yet is obligated by the Protective Order at ¶ 6 to seek to redact two references to an individual's name and description of that witness that were contained in the Response and Reply. Those two references are highlighted on the attached exhibits. Those two references were derived from a document that the government marked "Confidential." The Court previously upheld the government's requested redaction of that individual's name from its Omnibus Response to Ms. Maxwell's Pretrial Motions and its accompanying Exhibit 7 (Dkt. No. 204-7), an email between the government and, inter alia, DOJ-OGR-00003986 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 245 Filed 04/23/21 Page 2 of 2 The Hon. Alison J. Nathan April 19, 2021 Page 2 Ms. McCawley of BSF. It is the privacy rights of this third-party witness that would be implicated by any public release. Because BSF does not know what materials have been exchanged in this criminal action or what has been designated confidential, BSF takes no position on whether the Defendant's proposed redactions are necessary. Respectfully submitted, Laura A. Menninger

Individual Pages

Page 1 - DOJ-OGR-00003986
Case 1:20-cr-00330-PAE Document 245 Filed 04/23/21 Page 1 of 2 Haddon, Morgan and Foreman, P.C Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com LMenninger@hmflaw.com April 19, 2021 The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 500 Pearl Street New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Redactions to Pleadings Re: Rule 17 Subpoenas Dear Judge Nathan: Counsel for Ms. Maxwell has conferred with Boies Schiller & Flexner (BSF) concerning any proposed redactions to the pleadings addressing the Rule 17(c) subpoena sub judice, specifically Defendant's Response of April 2 and BSF's Reply of April 5, both of which were submitted to the Court via email in order to allow an opportunity to address any necessary redactions. Ms. Maxwell is mindful of the Court's previous directive that any proposed redactions must be specifically justified and tailored yet is obligated by the Protective Order at ¶ 6 to seek to redact two references to an individual's name and description of that witness that were contained in the Response and Reply. Those two references are highlighted on the attached exhibits. Those two references were derived from a document that the government marked "Confidential." The Court previously upheld the government's requested redaction of that individual's name from its Omnibus Response to Ms. Maxwell's Pretrial Motions and its accompanying Exhibit 7 (Dkt. No. 204-7), an email between the government and, inter alia, DOJ-OGR-00003986
Page 2 - DOJ-OGR-00003987
Case 1:20-cr-00330-PAE Document 245 Filed 04/23/21 Page 2 of 2 The Hon. Alison J. Nathan April 19, 2021 Page 2 Ms. McCawley of BSF. It is the privacy rights of this third-party witness that would be implicated by any public release. Because BSF does not know what materials have been exchanged in this criminal action or what has been designated confidential, BSF takes no position on whether the Defendant's proposed redactions are necessary. Respectfully submitted, Laura A. Menninger