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Case 1:20-cr-00330-PAE Document 232 Filed 04/22/21 Page1of4
S U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Buildin, Seas ;
One Saint Andrew's Placa. PSHE Soak
New York, New York 10007 DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 4/22/21
April 20, 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:
The Government respectfully submits this letter in response to the Court’s April 16, 2021
Order (Dkt. 205) regarding whether the parties seek redactions to Reply Briefs 1, 3, 5, 6, and 10
and whether the parties seek redactions to certain exhibits or seek to file certain exhibits under
seal.
The parties have conferred in accordance with the Court’s April 16, 2021 Order. The
parties do not seek any redactions as to Reply Briefs 1 and 5 and, accordingly, the defense will file
those reply briefs on the public docket.
As to Exhibit A to Reply Brief 1, the Government respectfully submits that the exhibit
should be filed entirely under seal in order to protect the privacy interests of victims and third
parties. The defense has indicated that it has no objection to filing Exhibit A on the public record.
As to Reply Brief 3, the Government respectfully requests that the Court adopt the
redactions the defense had originally proposed on page 3 on March 15, 2021, which are narrowly
tailored to cover information implicating the personal privacy interests of victims and third parties.
DOJ-OGR- 00003931