Case 1:20-cr-00330-PAE Document 359 Filed 10/18/21 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
October 18, 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 its motions in limine, which the Government is submitting to the Court under seal by email with proposed redactions. 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 Government's motions in limine are judicial documents subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims—including victims who have not identified themselves on the record in this case and who have not publicly identified themselves as victims referenced in the Indictment in this case—and third parties referenced in the document.
In addition, the Government seeks redaction of Section X at least until the conclusion of trial. Additional justification for this sealing request is located in footnote 11 on page 49 of the Government's motions in limine.
DOJ-OGR-00005264
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Document 359
AI Analysis
Summary: The US Attorney's Office for the Southern District of New York submits a motion to file its motions in limine with proposed redactions to protect victim and third-party privacy. The redactions are justified under the Lugosch v. Pyramid Co. of Onondaga test. The government requests the court to permit the filing with redactions.
Significance: This document is potentially important because it reveals the government's request to redact certain information from its motions in limine to protect the privacy interests of victims and third parties in the Ghislaine Maxwell case.
Key Topics:
Motions in limine
Redaction requests
Sealing of court documents
Key People:
- Alison J. Nathan - United States District Judge
- Ghislaine Maxwell - Defendant
- Damian Williams - 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 359 Filed 10/18/21 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
October 18, 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 its motions in limine, which the Government is submitting to the Court under seal by email with proposed redactions. 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 Government's motions in limine are judicial documents subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims—including victims who have not identified themselves on the record in this case and who have not publicly identified themselves as victims referenced in the Indictment in this case—and third parties referenced in the document.
In addition, the Government seeks redaction of Section X at least until the conclusion of trial. Additional justification for this sealing request is located in footnote 11 on page 49 of the Government's motions in limine.
DOJ-OGR-00005264
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Case 1:20-cr-00330-PAE Document 359 Filed 10/18/21 Page 2 of 2
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Accordingly, the Government respectfully requests that the Court permit the Government to publicly file its motions in limine with its proposed redactions.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By: s/
Alison Moe
Lara Pomerantz
Andrew Rohrbach
Assistant United States Attorneys
Southern District of New York
Cc: Defense counsel (By ECF)
DOJ-OGR-00005265
Individual Pages
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Case 1:20-cr-00330-PAE Document 359 Filed 10/18/21 Page 2 of 2
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Accordingly, the Government respectfully requests that the Court permit the Government to publicly file its motions in limine with its proposed redactions.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By: s/
Alison Moe
Lara Pomerantz
Andrew Rohrbach
Assistant United States Attorneys
Southern District of New York
Cc: Defense counsel (By ECF)
DOJ-OGR-00005265