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Case 1:20-cr-00330-PAE Document tf Filed 03/22/21 Page 1 of 2
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
March 22, 2021
BY ECF & ELECTRONIC MAIL
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:
In accordance with the Court’s March 18, 2021 order (the “Order’’), the parties have met and
conferred regarding proposed redactions to Exhibit 11 and the defendant’s cover letter dated March
9, 2021. The parties have reached agreement regarding redactions as to Exhibit 11 and the
defendant’s cover letter. The parties do not believe any redactions are needed as to the defendant’s
cover letter. The parties’ proposed redactions to Exhibit 11 are submitted under seal for the Court’s
consideration.
The Government intends to file its omnibus memorandum of law and the corresponding
exhibits consistent with the Court’s Order, with one exception to which the defense consents. In
particular, the defense has indicated that it no longer wishes the Government to remove the redactions
the Government had originally proposed to pages 118 to 119 of the Government’s brief. Those
redactions refer to and quote from portions of an exhibit filed under seal by the defense and which
the Government understands is filed under seal in Giuffre v. Maxwell, 15 Civ. 7433 (LAP).
Accordingly, the Government has kept those redactions in the attached omnibus memorandum of law.
Additionally, and mindful of the presumption of public access, the Government notes that
some of the defense’s proposed redactions which the Court adopted in the Order include language
DOJ-OGR-00002779