Document 506

The Morgan Account GOVERNMENT EXHIBIT 506 S2 20 Cr. 330 (AJN) Month Date Year Account title (SOURCE ONE BELOW) Social Security no. / Tax ID no. / Passport no. Account type Account number Account type Account number BAC # All Accountholders/Signers must sign this Signature Form exactly as the checks/instructions will be signed. Print (Accountholder/Signer, Trustee, Custodian, Director, etc.) Title Sign Here Ghislaine MAXwell, President X If facsimile signature, check box Print (Joint Accountholder/Signer, Trustee, Custodian, Director, etc.) Title Sign Here Harry Beller, Secretary X If facsimile signature, check box Print (other) Title Sign Here X If facsimile signature, check box Print (other) Title Sign Here X If facsimile signature, check box Is this an existing account? yes no If yes, does this card replace all other cards against this account? yes no Signing instructions (Please use back of card if necessary) The Morgan Account Month Date Year Account title (SOURCE ONE BELOW) Social Security no. / Tax ID no. / Passport no. Account type Account number Account type Account number BAC # All Accountholders/Signers must sign this Signature Form exactly as the checks/instructions will be signed. Print (Accountholder/Signer, Trustee, Custodian, Director, etc.) Title Sign Here Ghislaine Maxwell, President X If facsimile signature, check box Print (Joint Accountholder/Signer, Trustee, Custodian, Director, etc.) Title Sign Here Harry Beller, Secretary X If facsimile signature, check box Print (other) Title Sign Here X If facsimile signature, check box Print (other) Title Sign Here X If facsimile signature, check box Is this an existing account? yes no If yes, does this card replace all other cards against this account? yes no Signing instructions (Please use back of card if necessary) 1342 1 page 11/15/06 104 Confidential Treatment Requested by JPMorgan Chase JPM-SDNY-00002410 DOJ-OGR-00015715 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 506 Filed 11/24/21 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 24, 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. 495, the Government submits proposed redactions to the filings associated with the Government's motion to preclude six defense experts. In addition to the proposed redactions, the Government respectfully seeks to redact Government Exhibit A, the defense expert notice, which the Government has filed on the docket with the same redactions (see Dkt. No. 424-1), and moves to file Government Exhibit B under seal. The Government's proposed redactions and sealing 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' 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, including a Minor Victim who is a subject of the Court's pseudonym order. The defense has informed the Government that it is not seeking any additional redactions. DOJ-OGR-00008040 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 506 Filed 11/24/21 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-00008041