Epstein Project

617.pdf

Type
pdf
Source set
house-oversight-doj
Pages
3
Text status
Searchable text available
OCR confidence
0.9407898314854373

Original source

Extracted text

Case 1:20-cr-00330-PAE Document617 Filed 02/24/22 Pagelof3 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 January 13, 2022 By Email 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, 82 20 Cr. 330 (AJN) Dear Judge Nathan: Counsel for Juror 50 has filed a motion to intervene, and to obtain a copy of certain materials relating to jury selection. The motion was submitted by email to Chambers. In an Order dated January 12, 2022, the Court directed the parties “to submit via email any proposed redactions on or before January 13, 2022, justifying any such request by reference to the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006).” The Government respectfully submits that no redactions are necessary, and accordingly the motion should be publicly filed. The defendant opposes any public filing of Juror 50’s motion, arguing that it is not a judicial document. This argument is meritless. Juror 50’s motion to intervene is quite obviously “relevant to the performance of a judicial function and useful in the judicial process.” United States DOJ-OGR- 00009537 

Case 1:20-cr-00330-PAE Document617_ Filed 02/24/22 Page2of3 v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995); see also S-E.C. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001) (noting that a “document which is presented to the court to invoke its powers or affect its decisions” stands on a “different footing” than items merely passed between parties in discovery). The defendant’s letter previews her argument on the merits of Juror 50’s motion to intervene, which the parties have not yet briefed, yet ignores that the motion is a judicial document whether or not the Court ultimately grants the motion. See Lu…

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