Document 498

Case 1:20-cr-00330-PAE Document 498 Filed 11/23/21 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 23, 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. 482, the Government seeks redactions to Exhibit 1 to the defendant's response to the Government's motion to preclude the testimony of Dr. Dietz and Dr. Loftus. 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 third parties, including individuals who have not identified themselves on the record in this case, and who are subjects of the Court's pseudonym order. The Government does not seek redactions to the defense response or the Court's Opinion & Order. The defense has informed the Government that it is not seeking any additional redactions. DOJ-OGR-00007464 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 498 Filed 11/23/21 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-00007465