Document 324

GOVERNMENT EXHIBIT 324 S2 20 Cr. 330 (AJN) DOJ-OGR-00015646 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 324 Filed 08/20/21 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 August 20, 2021 VIA 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 writes in response to defense counsel's letter of August 19, 2021 (Dkt. No. 323). The Court denied defense counsel's sealed, ex parte motion for an order authorizing four Rule 17(c)(3) subpoenas in a sealed opinion dated August 13, 2021, and the Court ordered defense counsel to inform the Court whether they seek any sealing or redactions. (Dkt. No. 318). The defense has responded that they seek no redactions, and that they believe the burden to justify any redactions is on the Government. (Dkt. No. 323). Because the Government does not have a copy of the sealed motion papers or the Court's Opinion and Order, the Government is unable to propose or justify any redactions. For instance, it appears that the motion papers include the names of victims and potential witnesses (id. at 1), which the Government would likely move to redact. The Government has conferred with defense counsel, who have informed the Government that they are unable to provide a copy of those documents absent further order of this Court. Accordingly, the Government moves for a limited DOJ-OGR-00005007 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 324 Filed 08/20/21 Page 2 of 2 Honorable Alison J. Nathan August 20, 2021 Page 2 unsealing of the Court's August 13, 2021 opinion and the underlying motion papers so that the Government may review those documents and propose any redactions. Respectfully submitted, AUDREY STRAUSS United States Attorney By: /s/ Alison Moe / Maurene Comey / Lara Pomerantz / Andrew Rohrbach Assistant United States Attorneys Southern District of New York Tel: (212) 637-2225 Cc: All counsel of record (by ECF) DOJ-OGR-00005008