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CéSasb: 2@20rOCRRSPAGN DenwmeantBe2 AbslOesis221 Patpege afdf 3
U.S. Department of Justice
United States Attorney
Southern District of New York
PRESS : The Silvio J. Mollo Building
USDC SDNY One Saint Andrew’s Plaza
DOCUMENT New York, New York 10007
ELECTRONICALLY FILED
DOC #:
DATE FILED:_ 9/3/21 September 1, 2021
The Court has reviewed the proposed redactions and finds that they are
BY ECF narrowly tailored and necessary to protect the privacy and identities of
third parties not identified on the record in this case. The intended
The Honorable Alison J. Nathan |recipients of the subpoenas did not file proposed redactions by September
United States District Court 1, 2021, per this Court's August 23 Order. Dkt. No. 325. The Court
Southern District of New York accordingly ORDERS Defendant to file the redacted Motion and Exhibits
United States Courthouse 1, 3, and 4, and unredacted Exhibit 2, by September 7, 2021. The Court
40 Foley Square hereby unseals the August 13 Opinion, and the Court will file the Opinion
New York, New York 10007 on the public docket. SO ORDERED.
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Ae 0 igor
9/2/21
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-00005027