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Document 498

AI Analysis

Summary: The Government, led by United States Attorney Damian Williams, is seeking redactions to a specific exhibit in the Ghislaine Maxwell case to protect the privacy of minor victims and third parties, in accordance with the Lugosch v. Pyramid Co. of Onondaga test. The proposed redactions are limited and do not apply to the defense response or the Court's Opinion & Order. The defense has not requested additional redactions.
Significance: This document is significant because it reveals the Government's efforts to balance the need for transparency in court proceedings with the need to protect the privacy of minor victims and other individuals involved in the case.
Key Topics: Redactions to court documents Protection of minor victims' privacy Application of the Lugosch v. Pyramid Co. of Onondaga test
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
Court Filing
Date
November 23, 2021
Pages
2
Folder
IMAGES003

Full Text

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

Individual Pages

Page 1 - DOJ-OGR-00007464
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 2 - DOJ-OGR-00007465
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