Document Case 1:20-cr-00320-AJN Document 472 Filed 08/21/20 Page 3 of 354

Case 1:20-cr-00320-AJN Document 472 Filed 08/21/20 Page 3 of 354 Honorable Alison J. Nathan August 21, 2020 Page 3 Here, even assuming the materials at issue constitute judicial documents, any presumption in favor of access is overcome because of the nature of the documents themselves, namely materials related to a grand jury investigation. As described above, the grand jury investigation is active and ongoing, and resulted in new charges being brought just last month in this case. [REDACTED] In sum, the Government respectfully submits that the exhibits to the Defense Letter, which consist entirely of filings that have been ordered sealed by other judicial officers, should similarly be filed under seal in this case while the grand jury investigation remains ongoing. For the same reasons, the Government proposes redacting any portions of the Defense Letter that [REDACTED]. Accordingly, the Government respectfully requests that the Court permit the redactions to the Defense Letter proposed in Exhibit A hereto and that both the unredacted Defense Letter and the exhibits thereto remain under seal until further order of the Court. Additionally, because the instant letter discusses the Government's ongoing investigation and references [REDACTED], the Government also respectfully requests that it be permitted to file a redacted version of this letter on the public docket and that the unredacted version of this letter as well as Exhibit A to this letter be filed under seal. App.097 DOJ-OGR-00019556