Case 1:20-cr-00330-AJN Document 162 Filed 02/26/21 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
February 26, 2021
BY ECF & ELECTRONIC MAIL
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 submits under seal the enclosed unredacted version of its memorandum of law and accompanying exhibits in opposition to the defendant's twelve pre-trial motions. Additionally, the Government respectfully submits proposed redactions to its memorandum of law and three exhibits, Exhibits 1, 5, and 7. Consistent with the redactions contained in the defendant's motions, the Government's proposed redactions are narrowly tailored to (1) cover information implicating the privacy interests of third parties, (2) cover Confidential Material produced by the Government in discovery and governed by paragraph 15 of the Protective Order in this case (Dkt. 36), (3) cover information submitted under seal to other judicial officers or information another judicial officer has determined should remain under seal, and (4) protect the integrity of the Government's ongoing investigation.
In addition, the Government respectfully requests that certain exhibits be filed entirely under seal. In particular, the Government respectfully submits that (1) Exhibits 8 and 9, filings submitted under seal to other judicial officers, should similarly be filed under seal in this case while the Government's grand jury investigation remains ongoing; and (2) Exhibit 11 should be filed under seal because it contains information which another judicial officer has determined should remain under seal.
DOJ-OGR-00002742
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Document 162
AI Analysis
Summary: The document is a letter from the US Attorney's Office to Judge Alison J. Nathan, requesting to file certain court documents under seal or with redactions to protect sensitive information. The government is submitting an unredacted version of their memorandum of law and exhibits in opposition to the defendant's pre-trial motions, while proposing redactions to certain documents to protect third-party privacy and the integrity of their investigation.
Significance: This document is significant because it reveals the government's efforts to balance the need for transparency in court proceedings with the need to protect sensitive information, including the privacy interests of third parties and the integrity of their ongoing investigation.
Key Topics:
Sealing of court documents
Redactions to court filings
Protective Order and Confidential Material
Key People:
- Alison J. Nathan - United States District Judge
- Ghislaine Maxwell - Defendant
- Audrey Strauss - 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
Full Text
Case 1:20-cr-00330-AJN Document 162 Filed 02/26/21 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
February 26, 2021
BY ECF & ELECTRONIC MAIL
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 submits under seal the enclosed unredacted version of its memorandum of law and accompanying exhibits in opposition to the defendant's twelve pre-trial motions. Additionally, the Government respectfully submits proposed redactions to its memorandum of law and three exhibits, Exhibits 1, 5, and 7. Consistent with the redactions contained in the defendant's motions, the Government's proposed redactions are narrowly tailored to (1) cover information implicating the privacy interests of third parties, (2) cover Confidential Material produced by the Government in discovery and governed by paragraph 15 of the Protective Order in this case (Dkt. 36), (3) cover information submitted under seal to other judicial officers or information another judicial officer has determined should remain under seal, and (4) protect the integrity of the Government's ongoing investigation.
In addition, the Government respectfully requests that certain exhibits be filed entirely under seal. In particular, the Government respectfully submits that (1) Exhibits 8 and 9, filings submitted under seal to other judicial officers, should similarly be filed under seal in this case while the Government's grand jury investigation remains ongoing; and (2) Exhibit 11 should be filed under seal because it contains information which another judicial officer has determined should remain under seal.
DOJ-OGR-00002742
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Case 1:20-cr-00330-AJN Document 162 Filed 02/26/21 Page 2 of 2
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Accordingly, the Government respectfully requests that the Court permit the Government to publicly file its memorandum of law and exhibits with the enclosed proposed redactions.
Respectfully submitted,
AUDREY STRAUSS
United States Attorney
By: s/
Maurene Comey / Alison Moe / Lara Pomerantz / Andrew Rohrbach
Assistant United States Attorneys
Southern District of New York
Cc: All Counsel of Record (By email)
DOJ-OGR-00002743
Individual Pages
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Case 1:20-cr-00330-AJN Document 162 Filed 02/26/21 Page 2 of 2
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Accordingly, the Government respectfully requests that the Court permit the Government to publicly file its memorandum of law and exhibits with the enclosed proposed redactions.
Respectfully submitted,
AUDREY STRAUSS
United States Attorney
By: s/
Maurene Comey / Alison Moe / Lara Pomerantz / Andrew Rohrbach
Assistant United States Attorneys
Southern District of New York
Cc: All Counsel of Record (By email)
DOJ-OGR-00002743