Case 1:20-cr-00330-PAE
Cy
HADDON
MORGAN
FOREMAN
May 21, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Souther District of New York
40 Foley Square
New York, NY 10007
Document 289
Filed 05/21/21 Page 1of2
Haddon, Morgan and Foreman, P.c
Jeffrey S. Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364 Fx 303.832.2628
www.hmflaw.com
[email protected]
Re: — Reply to Government Letter dated May 14 Regarding Proposed Redactions to Ms.
Maxwell’s May 12, 2021 Letter (DE 283),
United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
On May 14, 2021, the government requested that Exhibits A and B to Ms. Maxwell’s
May 12, 2021 Letter Response to the Government’s Letters dated May 4, and May 6, 2021
regarding F.R. Crim. P. 17(c) subpoena remain sealed. Ms. Maxwell respectfully disagrees, for
the following reasons:
Exhibit A, a journal entry, was produced to Ms. Maxwell by Accuser-2 in civil discovery.
The document production was not subject to any protective order and this exhibit was not
produced to Ms. Maxwell by the government. As detailed in Ms. Maxwell’s Response to the
Government’s Letters dated May 4, and May 6, 2021 regarding F.R. Crim. P. 17(c) subpoena,
Accuser-2 has publicly discussed her journal, generally, and this entry specifically. Exhibit B
appears to be a different copy of Exhibit A.
The government has offered no reason why either Exhibit should remain sealed. The
Exhibits are “judicial documents” presumptively subject to the public access rights under both
DOJ-OGR-00004247