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__ Case 1:20-cr-00330-PAE Document 288 Filed 05/20/21 Page 1 of 2
aN 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
May 20, 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 17, 2021, which directed the Government to confer with defense counsel and submit proposed
redactions to Exhibit C to the defendant’s memorandum in support of her supplemental pre-trial
motions. (Dkt. No. 284).
The Government seeks redactions that are narrowly tailored to protect the privacy interests
of victims and third parties referenced in the document. 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). Today the Government is submitting to the Court by email its
proposed redactions to Exhibit C, which the Government respectfully requests be filed under seal.
DOJ-OGR-00004245