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Document 481

AI Analysis

Summary: The document is a letter from the US Attorney's office to Judge Alison J. Nathan, submitting proposed redactions to supplemental briefing related to Witness-3 in the Ghislaine Maxwell case, citing the need to protect Witness-3's privacy and referencing sealed materials from Rule 412 litigation.
Significance: This document is significant because it reveals the government's efforts to balance the public's right to access court documents with the need to protect the privacy of a witness in a high-profile case.
Key Topics: Proposed redactions to supplemental briefing Privacy interests of Witness-3 Application of the Lugosch v. Pyramid Co. test for redactions
Key People:
  • Alison J. Nathan - United States District Judge
  • Ghislaine Maxwell - Defendant in the case
  • Damian Williams - United States Attorney
  • Witness-3 - Witness in the case, subject to pseudonym order
Document Type
Letter
Date
November 21, 2021
Pages
2
Folder
IMAGES003

Full Text

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

Individual Pages

Page 1 - DOJ-OGR-00007383
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 2 - DOJ-OGR-00007384
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