Document 288

Case 1:20-cr-00330-PAE Document 288 Filed 05/20/21 Page 1 of 2 U.S Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 May 20, 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 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court's Order dated May 17, 2021, which directed the Government to confer with defense counsel and submit proposed redactions to Exhibit C to the defendant's memorandum in support of her supplemental pre-trial motions. (Dkt. No. 284). The Government seeks redactions that are narrowly tailored to protect the privacy interests of victims and third parties referenced in the document. These proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Today the Government is submitting to the Court by email its proposed redactions to Exhibit C, which the Government respectfully requests be filed under seal. DOJ-OGR-00004245 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 288 Filed 05/20/21 Page 2 of 2 Page 2 The Government has conferred with defense counsel in accordance with the Order. The defense has indicated that it has no objection to the Government's proposed redactions to Exhibit C. Respectfully submitted, AUDREY STRAUSS United States Attorney By: s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense counsel (By ECF) DOJ-OGR-00004246