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Case 1:20-cr-00330-PAE Document 284 Filed 05/17/21 Pagelof2
aN U.S. Department of Justice
lio
United States Attorney || uspc spny
Southern District of Ne\|| DOCUMENT
The Silvio J. Mollo Building Dac #:
ELECTRONICALLY FILED ||
One Saint Andrew's Plaza
New York, New York 10007
DATE FILED: 5/17/21
May 12, 2021
BY ECF
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 Order dated
May 10, 2021, which directed the Government to propose and justify any requests for redaction of
the defendant’s memorandum in support of her supplemental pre-trial motions and exhibits. (Dkt.
No. 274).
After reviewing the defense’s memorandum, the Government seeks a limited number of
redactions. These proposed redactions are consistent with the three-part test articulated by the
Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although
the defense’s memorandum in support of her supplemental pre-trial motions is a judicial document
subject to the common law presumption of access, the proposed redactions are narrowly tailored
to protect the privacy interests of victims and third parties referenced in the document. These
redactions are thus consistent with similar, tailored redactions permitted by the Court in this case
to protect the privacy interests of third parties. (See, e.g., Dkt. No. 168, 232). Today the
Government is submitting to the Court by email its proposed redactions to the defense’s
memorandum, which the Government respectfully requests be filed under seal.
DOJ-OGR-00004134