Case 1:20-cr-00330-PAE Document 486 Filed 11/22/21 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
November 22, 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:
Pursuant to the Court's Orders at Dkt. Nos. 473, 474, and 476, the parties are docketing today the Government's motion to quash the defendant's Rule 17(c) subpoena, proposed redacted versions of the Government's letter motion of November 18, 2021 and the defendant's response, and proposed redacted versions of the defendant's response relating to Government Exhibit 52 and the Government's reply.
The defense has informed the Government that they are not seeking redactions to these filings.
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 parties' supplemental briefing and the Court's Opinion & Order are judicial documents subject to the common law presumption of access, the limited proposed redactions are narrowly tailored to protect the privacy interests of the Minor Victims and witnesses, including individuals who have not identified themselves on the record in this case, and who are subjects of the Court's pseudonym order.
DOJ-OGR-00007391
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Document 486
AI Analysis
Summary: The document is a letter from the US Attorney's Office to Judge Alison J. Nathan, informing her that the government is filing a motion to quash a subpoena and related documents with proposed redactions to protect the privacy of minor victims and witnesses. The defense has indicated they are not seeking redactions.
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 of minor victims and witnesses in the Ghislaine Maxwell case.
Key Topics:
Redactions to court filings
Protection of minor victims' privacy
Compliance with court orders
Key People:
- Alison J. Nathan - United States District Judge
- Ghislaine Maxwell - Defendant
- Damian Williams - 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 486 Filed 11/22/21 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
November 22, 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:
Pursuant to the Court's Orders at Dkt. Nos. 473, 474, and 476, the parties are docketing today the Government's motion to quash the defendant's Rule 17(c) subpoena, proposed redacted versions of the Government's letter motion of November 18, 2021 and the defendant's response, and proposed redacted versions of the defendant's response relating to Government Exhibit 52 and the Government's reply.
The defense has informed the Government that they are not seeking redactions to these filings.
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 parties' supplemental briefing and the Court's Opinion & Order are judicial documents subject to the common law presumption of access, the limited proposed redactions are narrowly tailored to protect the privacy interests of the Minor Victims and witnesses, including individuals who have not identified themselves on the record in this case, and who are subjects of the Court's pseudonym order.
DOJ-OGR-00007391
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Case 1:20-cr-00330-PAE Document 486 Filed 11/22/21 Page 2 of 2
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Respectfully submitted,
DAMIAN WILLIAMS
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-00007392
Individual Pages
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Case 1:20-cr-00330-PAE Document 486 Filed 11/22/21 Page 2 of 2
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Respectfully submitted,
DAMIAN WILLIAMS
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-00007392