Document 546

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