232.pdf

Type

pdf

Source set

house-oversight-doj

Pages

4

Text status

Searchable text available

OCR confidence

0.9404995964362678

Original source

Extracted text

Case 1:20-cr-00330-PAE Document 232 Filed 04/22/21 Page1of4 Le, U.S. Department of Justice United States Attorney Southern District of New York   The Silvio J. Mollo Building One Saint Andrew’s Plaza USDC SDNY New York, New York 10007 DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 4/22/21   April 20, 2021 BY ECF & ELECTRONIC MAIL 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 April 16, 2021 Order (Dkt. 205) regarding whether the parties seek redactions to Reply Briefs 1, 3, 5, 6, and 10 and whether the parties seek redactions to certain exhibits or seek to file certain exhibits under seal. The parties have conferred in accordance with the Court’s April 16, 2021 Order. The parties do not seek any redactions as to Reply Briefs 1 and 5 and, accordingly, the defense will file those reply briefs on the public docket. As to Exhibit A to Reply Brief 1, the Government respectfully submits that the exhibit should be filed entirely under seal in order to protect the privacy interests of victims and third parties. The defense has indicated that it has no objection to filing Exhibit A on the public record. As to Reply Brief 3, the Government respectfully requests that the Court adopt the redactions the defense had originally proposed on page 3 on March 15, 2021, which are narrowly tailored to cover information implicating the personal privacy interests of victims and third parties. DOJ-OGR- 00003931 

Case 1:20-cr-00330-PAE Document 232 Filed 04/22/21 Page2of4 Page 2 The Government respectfully submits that the proposed redactions are consistent with the redactions ordered by the Court on March 18, 2021 as “the interest in protecting the safety and privacy of those individuals outweigh the presumption of access that atta…

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