Document 534

Case 1:20-cr-00330-PAE Document 534 Filed 12/09/21 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 December 9, 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: The Government respectfully seeks redactions to its letter motion for admission of Government Exhibit 52 (Dkt. No. 533), sealing of Exhibit A to that letter, and redactions to Exhibit B to that letter. 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 Government's letter and exhibits are judicial documents subject to the common law presumption of access, the limited proposed redactions and sealing are narrowly tailored to protect the privacy interests of the Minor Victims and witnesses, including individuals who are subjects of the Court's pseudonym order, as well as third parties. The Government also notes that the redactions to Exhibit B conform to redactions of that document in Giuffre v. Maxwell, 15 Civ. 7433 (LAP). DOJ-OGR-00008301 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 534 Filed 12/09/21 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-00008302