Case 1:20-cr-00330-PAE Document 283 Filed 05/14/21 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 14, 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 13, 2021, which directed the Government to propose and justify any requests for redaction of the defendant's response to the Government's letters of May 4 and May 6, 2021 and the attached exhibits. (Dkt. No. 279). DOJ-OGR-00004132
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Document 283
AI Analysis
Summary: The US Attorney's Office requests that Exhibits A and B be filed under seal in the Ghislaine Maxwell case, citing the need to protect the privacy interests of a victim and third party. The request is made in response to the court's order and is justified under the three-part test articulated in Lugosch v. Pyramid Co. of Onondaga. The government argues that sealing the exhibits is narrowly tailored to protect these interests.
Significance: This document is potentially important as it reveals the government's request to seal certain exhibits in the Ghislaine Maxwell case, citing privacy interests of a victim and third party.
Key Topics:
Request for Redaction
Sealing of Exhibits
Privacy Interests
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 283 Filed 05/14/21 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 14, 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 13, 2021, which directed the Government to propose and justify any requests for redaction of the defendant's response to the Government's letters of May 4 and May 6, 2021 and the attached exhibits. (Dkt. No. 279). DOJ-OGR-00004132
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Case 1:20-cr-00330-PAE Document 283 Filed 05/14/21 Page 2 of 2
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After reviewing the defense's letter and exhibits, the Government respectfully submits that Exhibits A and B should be filed under seal. This proposal is 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 letter and exhibits are judicial documents subject to the common law presumption of access, sealing the exhibits—each of which is only one page—is narrowly tailored to protect the privacy interests of a victim and third party implicated in the documents. The Court has accepted other exhibits under seal or in redacted form 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)
Individual Pages
Page 1 of 2 - DOJ-OGR-00004132
Page 2 - DOJ-OGR-00004133
Case 1:20-cr-00330-PAE Document 283 Filed 05/14/21 Page 2 of 2
Page 2
After reviewing the defense's letter and exhibits, the Government respectfully submits that Exhibits A and B should be filed under seal. This proposal is 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 letter and exhibits are judicial documents subject to the common law presumption of access, sealing the exhibits—each of which is only one page—is narrowly tailored to protect the privacy interests of a victim and third party implicated in the documents. The Court has accepted other exhibits under seal or in redacted form 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)