Case 1:20-cr-00330-PAE Document 217 Filed 04/19/21 Page1of6
Haddon, Morgan and Foreman, P.c
Laura A. Menninger
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364 Fx 303.832.2628
www.hmilaw.com
[email protected]
HADDON
MORGAN
FOREMAN
April 1, 2021
The Hon. Alison J. Nathan
United States District Court Judge
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Joint Letter Concerning Redactions to Omnibus Response & Exhibit 11
Dear Judge Nathan:
Pursuant to this Court’s Order of March 29, 2021 (Dkt. No. 189), the parties
respectfully submit this joint letter concerning redactions to the Omnibus Memorandum in
Opposition to the Defendant’s Pre-Trial Motions (“Response’’).
Joint Position
The parties no longer seek the proposed redactions to pages 118 and 119 of the
government’s Response.
Ms. Maxwell’s Position
Ms. Maxwell seeks to redact from pages 129-134 of the Response and from Exhibit 11
only those portions of her July 22, 2016 deposition as to which Judge Preska ruled:
public access to [these] parts of the transcript is outweighed by Ms. Maxwell's
countervailing interests in resisting disclosure of the details of her private,
intimate relationships with consenting adults. This testimony is, in any case, far
afield from the sex trafficking and sexual abuse allegations that were central to
the dispute in Giuffre v. Maxwell. Although the prurient interest of some may
be left unsatiated as a result, Ms. Maxwell's interest in keeping private the
details of her sexual relationships with consenting adults warrants the sealing
of those portions of her testimony (and any materials that reference them).
DOJ-OGR-00003847