EFTA00017805.pdf

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pdf

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data-set-8

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Case 1:20-cr-00330-AJN Document 46 Filed 08/21/20 Page 1 of 5 
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 
August 21, 2020 
VIA 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 this letter in opposition to the defendant's letter of 
August 17, 2020 (the "Defense Letter"), requesting that the Court enter an order permitting the 
defendant to file under seal in certain civil cases (the "Civil Cases") discovery materials produced 
by the Government in the instant criminal case, and to refer to, but not file, additional other 
discovery materials produced by the Government in the Civil Cases. Those applications should 
be denied.' 
As an initial matter, the Government has already produced, and will continue to produce, 
substantial volumes of materials in discovery consistent with its obligations. Those include 
materials the Government obtained via search warrant, grand jury subpoenas, or other investigative 
methods available only to the Government. Indeed, the Government has already produced more 
than 165,000 pages of discovery to the defense, including the materials relevant to the Defense 
Letter. Through her most recent application, the defendant seeks permission to use, in unrelated 
civil litigation, materials produced pursuant to the protective order in this case and designated 
"Confidential" thereunder. 
As detailed herein, the Government's designation is entirely 
appropriate given that the materials—court orders and applications—have been kept under seal by 
the issuing judges, and pertain to an ongoing criminal investigation. 
' The Government has drafted this letter in a manner that avoids revealing the con…

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