332 [DOJ-OGR-00005024—DOJ-OGR-00005026]

Case 1:20-cr-00330-PAE Document 332 Filed 09/01/21 Page1of3 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 September 1, 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 August 23, 2021, which directed the Government to propose and justify any requests for redaction of the Court’s temporarily sealed August 13, 20201 Opinion and Order and the underlying motion papers. (Dkt. No. 325). After reviewing the Court’s August 13 Opinion and Order, the Government agrees with the defense that no redactions are necessary to that document and accordingly has no objection to the public filing of that document in its entirety. After reviewing the underlying motion papers, the Government respectfully submits that portions of those papers should be redacted. With respect to Ms. Maxwell’s Second Ex Parte and In Camera Motion for an Order Authorizing a Subpoena Pursuant to Fed. R. Crim. P. 17(c)(3) (the ‘“Motion”), the Government respectfully submits that limited redactions are appropriate to protect the privacy interests of victims who have not identified themselves on the record in this case and the privacy interests of third parties referenced in the Motion. With respect to Exhibit 1 to the Motion, the Government respectfully submits that the journal entries and photographs contained in Exhibits A, B, and C to Exhibit 1 should be redacted in their entirety to protect the privacy DOJ-OGR-00005024