399 [DOJ-OGR-00006023—DOJ-OGR-00006026]

Case 1:20-cr-00330-PAE Document 399 _ Filed 10/29/21 Page1of4 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 October 28, 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 concerning the parties’ motions in /imine. Consistent with the Court’s order (Dkt. No. 368), the parties today have filed their motions in limine and responsive briefs, containing all redactions sought by both parties. The following are the parties’ justifications for their proposed redactions: Government’s Justification The Government’s 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 Government’s motions in limine are judicial documents subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims (including victims who have not identified themselves on the record in this case and who have not publicly identified themselves as victims referenced in the Indictment in this case), witnesses, and third parties. The Government also seeks sealing of trial exhibits, which are not public, and certain other exhibits which are not themselves confidential, but which would risk identifying the victims if publicly filed on the docket in this case. DOJ-OGR-00006023