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Document 486

AI Analysis

Summary: The document is a letter from the US Attorney's Office to Judge Alison J. Nathan, informing her that the government is filing a motion to quash a subpoena and related documents with proposed redactions to protect the privacy of minor victims and witnesses. The defense has indicated they are not seeking redactions.
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 minor victims and witnesses in the Ghislaine Maxwell case.
Key Topics: Redactions to court filings Protection of minor victims' privacy Compliance with court orders
Key People:
  • Alison J. Nathan - United States District Judge
  • Ghislaine Maxwell - Defendant
  • Damian Williams - United States Attorney
  • Maurene Comey - Assistant United States Attorney
  • Alison Moe - Assistant United States Attorney
  • Lara Pomerantz - Assistant United States Attorney
  • Andrew Rohrbach - Assistant United States Attorney
Document Type
Letter
Date
11/22/21
Pages
2
Folder
IMAGES003

Full Text

Case 1:20-cr-00330-PAE Document 486 Filed 11/22/21 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 22, 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 Orders at Dkt. Nos. 473, 474, and 476, the parties are docketing today the Government's motion to quash the defendant's Rule 17(c) subpoena, proposed redacted versions of the Government's letter motion of November 18, 2021 and the defendant's response, and proposed redacted versions of the defendant's response relating to Government Exhibit 52 and the Government's reply. The defense has informed the Government that they are not seeking redactions to these filings. 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 the Minor Victims and witnesses, including individuals who have not identified themselves on the record in this case, and who are subjects of the Court's pseudonym order. DOJ-OGR-00007391 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 486 Filed 11/22/21 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-00007392

Individual Pages

Page 1 - DOJ-OGR-00007391
Case 1:20-cr-00330-PAE Document 486 Filed 11/22/21 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 22, 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 Orders at Dkt. Nos. 473, 474, and 476, the parties are docketing today the Government's motion to quash the defendant's Rule 17(c) subpoena, proposed redacted versions of the Government's letter motion of November 18, 2021 and the defendant's response, and proposed redacted versions of the defendant's response relating to Government Exhibit 52 and the Government's reply. The defense has informed the Government that they are not seeking redactions to these filings. 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 the Minor Victims and witnesses, including individuals who have not identified themselves on the record in this case, and who are subjects of the Court's pseudonym order. DOJ-OGR-00007391
Page 2 - DOJ-OGR-00007392
Case 1:20-cr-00330-PAE Document 486 Filed 11/22/21 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-00007392