Case 1:20-cr-00330-PAE Document 498 Filed 11/23/21 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 23, 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 Order at Dkt. No. 482, the Government seeks redactions to Exhibit 1 to the defendant's response to the Government's motion to preclude the testimony of Dr. Dietz and Dr. Loftus. 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 third parties, including individuals who have not identified themselves on the record in this case, and who are subjects of the Court's pseudonym order.
The Government does not seek redactions to the defense response or the Court's Opinion & Order. The defense has informed the Government that it is not seeking any additional redactions.
DOJ-OGR-00007464
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CA:
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Document 498
AI Analysis
Summary: The Government, led by United States Attorney Damian Williams, is seeking redactions to a specific exhibit in the Ghislaine Maxwell case to protect the privacy of minor victims and third parties, in accordance with the Lugosch v. Pyramid Co. of Onondaga test. The proposed redactions are limited and do not apply to the defense response or the Court's Opinion & Order. The defense has not requested additional redactions.
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 the privacy of minor victims and other individuals involved in the case.
Key Topics:
Redactions to court documents
Protection of minor victims' privacy
Application of the Lugosch v. Pyramid Co. of Onondaga test
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 498 Filed 11/23/21 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 23, 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 Order at Dkt. No. 482, the Government seeks redactions to Exhibit 1 to the defendant's response to the Government's motion to preclude the testimony of Dr. Dietz and Dr. Loftus. 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 third parties, including individuals who have not identified themselves on the record in this case, and who are subjects of the Court's pseudonym order.
The Government does not seek redactions to the defense response or the Court's Opinion & Order. The defense has informed the Government that it is not seeking any additional redactions.
DOJ-OGR-00007464
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Case 1:20-cr-00330-PAE Document 498 Filed 11/23/21 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-00007465
Individual Pages
Page 1 - DOJ-OGR-00007464
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Case 1:20-cr-00330-PAE Document 498 Filed 11/23/21 Page 2 of 2
Page 2
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-00007465