EFTA00027704.pdf

Type: pdf
Source set: data-set-8
Extracted text

U.S. Department of Justice 
United States Attorney 
Southern District of New York 
The SiAdol Mollo Building 
One Saint Andrew's Plaza 
New York, New York 10007 
October 18, 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 (MN) 
Dear Judge Nathan: 
The Government respectfully submits its motions in limine, which the Government is 
submitting to the Court under seal by email with proposed redactions. 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 Government's motions in 
limine are judicial documents subject to the common law presumption of access, the proposed 
redactions are narrowly tailored to protect the privacy interests of victims—including victims who 
have not identified themselves on the record in this case and who have not publicly identified 
themselves as victims referenced in the Indictment in this case—and third parties referenced in the 
document. 
In addition, the Government seeks redaction of Section X at least until the conclusion of 
trial. Additional justification for this sealing request is located in footnote 11 on page 49 of the 
Government's motions in limine. 
EFTA00027704


Page 2 
Accordingly, the Government respectfully requests that the Court permit the Government 
to publicly file its motions in limine with its proposed redactions. 
Respectfully submitted, 
DAMIAN WILLIAMS 
United States Attorney 
By:  
s/ 
Assistant United States Attorneys 
Southern District of New York 
Cc: Defense counsel (By ECF) 
EFTA00027705
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