Document 410

Case 1:20-cr-00330-PAE Document 410 Filed 11/04/21 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 November 3, 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: Attached please find the parties' joint request to charge and proposed verdict sheet. The Government is docketing a redacted version today and submitting the unredacted versions to the Court. The redline text in the documents reflect the objections of the defense. Further detail of the parties' objections are contained in comment bubbles. The Government has proposed the only redactions in the Request to Charge. 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). Although the Government's request to charge is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of a third party. The Government is also providing under seal Exhibit A, which pertains to a defense comment. The defense informs the Government that this exhibit is a document from another case DOJ-OGR-00006065 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 410 Filed 11/04/21 Page 2 of 2 Page 2 that was not itself publicly docketed and therefore is submitting Exhibit A under seal. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By ECF) DOJ-OGR-00006066