Case 1:20-cr-00330-AJN Document 53 Filed 09/08/20 Page 1 of 3
My Haddon, Morgan and Foreman, P.c
Jeffrey Pagliuca
HADDON
tener Loctite 150 East 10th Avenue
FOREMAN Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
www.hmflaw.com
[email protected]
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
Re: Proposed Redactions to Request to Modify Protective Order (Under Seal)
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
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,
y
The government’s proposed redactions, however, go further and propose to redact
NS. The covernment would
have this Court redact lll
on the premise that it would “risk jeopardizing the
government’s investigation.”
1 To the extent this Court believes this letter also should be filed publicly, counsel also has indicated her proposed
redactions to this letter.
DOJ-OGR-00001760