EFTA00023662.pdf

Type: pdf
Source set: data-set-8

Extracted text

Haddon, Morgan and Foreman. r.c
Jeffrey Paglluca
HADDON
MORGAN
FOREMAN
pm
August 24, 2020
VIA EMAIL
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
150 East 10th Avenue
Denver. Colorado 80203
www.hmffaw.com
Re:
Proposed Redactions to Request to Modify Protective Order (Under Seal)
United States v. Ghislaine Maxwell, 20 Cr. 330 (MN)
Dear Judge Nathan,
In accordance with this Court's Order of August 18, 2020 (Doc. 44), Ms. Maxwell hereby
respectfully submits under seal her proposed redactions to her Request to Modify Protective
Order ("Request"), filed under seal on August 17, 2020. Ms. Maxwell also has filed her Reply
under seal and contemporaneously submits her proposed redactions to that pleading.'
Ms. Maxwell has no opposition to keeping under seal, and redacting from her Request and
Reply, the contents, description and discussion of the sealed materials themselves; because the
government has marked them Confidential, the Protective Order requires as much. See Doc. 36,
1 15.
The government's proposed redactions, however, go further and propose to redact significant
procedural background, all of which is publicly available information. The government would
have this Court redact the "snectttc civil suit Nom which the eovernment obtained matenals -
v. Maxwell lit ahon1
government's investigation."
on the premise that it would "risk jeopardizing the
p
i
IMs. Maxwell has already publicly and repeatedly pointed out in the
case, and to they
!second Circuit, that which was obvious from the outset of this crimi
c,
-- that her sealer
I To the extent this Court believes this letter also should be filed publicly, counsel also has indicated her proposed
redactions to this letter.
EFTA00023662

The Honorable Alison J. Nathan
August 24, 2020
Page 2
info ding unsex ing process and emergency stay, that she is seeking
'mod' y the protective order and revea
e…

Open in the interactive archive →