Document 481

Case 1:20-cr-00330-PAE Document 481 Filed 11/21/21 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 21, 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: Pursuant to the Court's Order at Dkt. No. 477, the Government is submitting today proposed redactions to the parties' supplemental briefing regarding Witness-3 and the Court's Memorandum Opinion & Order resolving those motions. The Government's 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 parties' supplemental briefing and the Court's Opinion & Order are judicial documents subject to the common law presumption of access, the limited proposed redactions are narrowly tailored to protect the privacy interests of Witness-3, who has not identified herself on the record in this case, and who is a subject of the Court's pseudonym order. In addition, some of the proposed redactions reference sealed materials from the Rule 412 litigation, which are "related materials" within the meaning of Fed. R. Evid. 412(c)(2). DOJ-OGR-00007383 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 481 Filed 11/21/21 Page 2 of 2 Page 2 Respectfully submitted, DAMIAN WILLIAMS 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-00007384