Case 1:20-cr-00330-PAE Document 278 Filed 05/12/21 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
May 12, 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 submits this letter in response to the Court's Order dated May 10, 2021, which directed the Government to propose and justify any requests for redaction of the defendant's memorandum in support of her supplemental pre-trial motions and exhibits. (Dkt. No. 274).
After reviewing the defense's memorandum, the Government seeks a limited number of redactions. These 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 defense's memorandum in support of her supplemental pre-trial motions is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims and third parties referenced in the document. These redactions are thus consistent with similar, tailored redactions permitted by the Court in this case to protect the privacy interests of third parties. (See, e.g., Dkt. No. 168, 232). Today the Government is submitting to the Court by email its proposed redactions to the defense's memorandum, which the Government respectfully requests be filed under seal.
DOJ-OGR-00004123
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Document 278
AI Analysis
Summary: The government submits a letter to Judge Alison J. Nathan requesting limited redactions to the defendant's memorandum and seeking to file certain exhibits under seal to protect the privacy interests of victims and third parties. The proposed redactions are justified under the three-part test articulated in Lugosch v. Pyramid Co. of Onondaga. The government is submitting proposed redactions to the Court by email.
Significance: This document is significant because it reveals the government's efforts to balance the public's right to access court documents with the need to protect the privacy interests of victims and third parties in a high-profile case.
Key Topics:
Redaction requests for defendant's memorandum
Protection of victims' and third parties' privacy interests
Sealing of certain exhibits
Key People:
- Ghislaine Maxwell - Defendant
- Alison J. Nathan - United States District Judge
- 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-PAE Document 278 Filed 05/12/21 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
May 12, 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 submits this letter in response to the Court's Order dated May 10, 2021, which directed the Government to propose and justify any requests for redaction of the defendant's memorandum in support of her supplemental pre-trial motions and exhibits. (Dkt. No. 274).
After reviewing the defense's memorandum, the Government seeks a limited number of redactions. These 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 defense's memorandum in support of her supplemental pre-trial motions is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims and third parties referenced in the document. These redactions are thus consistent with similar, tailored redactions permitted by the Court in this case to protect the privacy interests of third parties. (See, e.g., Dkt. No. 168, 232). Today the Government is submitting to the Court by email its proposed redactions to the defense's memorandum, which the Government respectfully requests be filed under seal.
DOJ-OGR-00004123
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Case 1:20-cr-00330-PAE Document 278 Filed 05/12/21 Page 2 of 2
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The Government respectfully submits that Exhibits C, E, F, G, H, and I should be filed entirely under seal in order to protect the privacy interests of victims and third parties implicated in the documents. The Court has accepted similar exhibits under seal in this case to protect such privacy interests. (See, e.g., Dkt. No. 168, 232).
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: Defense counsel (By ECF)
DOJ-OGR-00004124
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Case 1:20-cr-00330-PAE Document 278 Filed 05/12/21 Page 2 of 2
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The Government respectfully submits that Exhibits C, E, F, G, H, and I should be filed entirely under seal in order to protect the privacy interests of victims and third parties implicated in the documents. The Court has accepted similar exhibits under seal in this case to protect such privacy interests. (See, e.g., Dkt. No. 168, 232).
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: Defense counsel (By ECF)
DOJ-OGR-00004124