Case 1:20-cr-00330-AJN Document 87 Filed 12/04/20 Page 1 of 4
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COHEN & GRESSER LLP +1 212.957 7600 phone
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Mark S. Cohen
Christian R. Everdell
+1 (212) 957-7600
[email protected]
[email protected]
November 30, 2020
TO BE FILED UNDER SEAL
VIA EMAIL (SUBMITTED PURSUANT TO SECTION 2(B)
OF JUDGE NATHAN’S INDIVIDUAL PRACTICES IN CRIMINAL CASES)
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
AO Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response
to the Court’s order, dated November 25, 2020, directing Ms. Maxwell to justify why her letter
of the same date requesting an in camera conference to discuss confidentiality concerns related
to her Renewed Motion for Release on Bail (the “Motion”) should be sealed or redacted.
We continue to believe that sealing the November 25, 2020 letter (the “November 25"
Letter’) in its entirety is warranted and appropriate under the governing case law. However, in
response to the Court’s order, we ask the Court to file a redacted version of the November 25
Letter, attached hereto as Exhibit A, which redacts only the information necessary to protect
third parties from threats and harassment. In addition, because this letter must make reference to
the same confidential information contained in the November 25" Letter in order to justify the
proposed redactions, we further ask the Court to file a redacted version of this letter, attached as
Exhibit B. If the Court is not inclined to allow any of these redactions, we request leave to
withdraw both letters and refile the November 25" Letter with the redacted sentences deleted.
Every submission related to the Motion, including this letter, presents the defense with a
Catch-22. To support Ms. Maxwell’s position regarding sealing and confidentiality, we are
asked to provide the Court with specific information about the people supporting Ms. Maxwell’s
bail application and the need for sealing. But until we know what confidentiality protections the
Court is willing to put in place, we are obligated to protect these people from the potentially
devastating consequences of being publicly identified by divulging as little information about
them as possible. We therefore continue to believe that an in camera conference, attended by all
counsel, is the best way to address all of the confidentiality issues related to the Motion.
DOJ-OGR-00001855