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Document 546

AI Analysis

Summary: The US Attorney's Office requests redactions to Ghislaine Maxwell's letter motion and sealing of an exhibit to protect a minor victim's privacy, citing the Lugosch v. Pyramid Co. test. The proposed redactions are deemed narrowly tailored to protect the victim's privacy interests. The letter is submitted by the US Attorney's Office, signed by Damian Williams and several Assistant US Attorneys.
Significance: This document is potentially important because it reveals the government's efforts to protect the privacy of a minor victim in the Ghislaine Maxwell case by seeking redactions and sealing of certain documents.
Key Topics: Redaction request Sealing of exhibit Protection of minor victim's privacy
Key People:
  • Ghislaine Maxwell - Defendant
  • Alison J. Nathan - United States District Judge
  • 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
  • Jack Scarola - Witness
  • Brad Edwards - Witness
  • Robert Glassman - Witness
Document Type
Letter
Date
12/15/21
Pages
2
Folder
IMAGES003

Full Text

Case 1:20-cr-00330-PAE Document 546 Filed 12/15/21 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 15, 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 the defendant's letter motion seeking testimony of Jack Scarola, Brad Edwards, and Robert Glassman, and the sealing of Exhibit 1 to that letter (Dkt. No. 544). 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 letter and exhibit 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 a Minor Victim who is subject of the Court's pseudonym order. DOJ-OGR-00008383 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 546 Filed 12/15/21 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-00008384

Individual Pages

Page 1 of 2 - DOJ-OGR-00008383
Case 1:20-cr-00330-PAE Document 546 Filed 12/15/21 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 15, 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 the defendant's letter motion seeking testimony of Jack Scarola, Brad Edwards, and Robert Glassman, and the sealing of Exhibit 1 to that letter (Dkt. No. 544). 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 letter and exhibit 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 a Minor Victim who is subject of the Court's pseudonym order. DOJ-OGR-00008383
Page 2 - DOJ-OGR-00008384
Case 1:20-cr-00330-PAE Document 546 Filed 12/15/21 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-00008384