Document 486

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