sinpeda ees Case 1:20-cf-00330-PAE Document 451 Filed 11/12/2
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 11/12/21
The Court received the attached letters via
JemaiP@HE Dis@icPno longer permits public
access by telephone for in-court criminal
proceedings, including trials. The
memorandum can be found here - https://
e
Inner City PLESS risiercont le rogetn Te
proceedings in the case can be found here -
October 29, 2021 https://www.nysd.uscourts.gov/usa-vs-
ghislaine-maxwell-20-cr-330-ajn-case-
: information. The Court has impl ted
By E-mail to
[email protected] _| procedure for docketing filings with
proposed redactions and 1s ruling on the
i i str proposals as expeditiously as possible. See
Hon. Alison J. Nathan, United States District Judge ee Ol co ORDERED:
Southern District of New York, 40 Foley Square, New York, NY 10007 Me 0 | 7
Re: US v. Maxwell, 20-cr-330 (AJN), timely opposition to blanket requests to seal
’ . Te ; - 11/12/21
portions of motions in limine, trial exhibits, public access
Dear Judge Nathan:
On behalf of Inner City Press and in my personal capacity, I have been covering
the above-captioned case. This concerns in the first instance the flurry of motions
in limine filed earlier this evening, replete with redactions justified by the a
conclusory reference to Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d
Cir. 2006).
The Government's Justifications for redaction (Docket No. 399, docketed at 10:06
pm on Friday Oct 29) cites Lugosch then says "The Government also seeks sealing
of trial exhibits, where are not public.” Inner City Press immediately opposes this.
As one example within this motions of limine, the Government has redacted the
entirely of its Argument X, even the title and the page number. And as to trial
exhibits, see for example Judge Jed S. Rakoff's order in US v. Weigand, 20-cr-188
(JSR) https://www.documentcloud.org/documents/20536946-rakofforderonmrlicp
There, Judge Rakoff ordered the US Attorney's Office to make trial exhibit
available to the public at large. While this was done, belatedly, in US v. Parnas, it
was refused in the current US v. Cole. It cannot be refused in this case.
Also, Inner City Press understands that the listen-only call-in telephone lines
available so far in the case, there may be an attempt to discontinue them. The Court
should take judicial notice of continue COVID-19 issues, including people's
understandable concerns about congregating even in so-called overflow rooms. Be
aware that the District for the District of Columbia still allows public phone access
to all criminal proceedings, even those held in-person. That should happen here.
The loss of First Amendment freedoms, even for a short period of time,
unquestionably constitutes irreparable injury. Elrod v. Burns, 427 U.S. 347, 373
(1976).
Inner City Press: In-house SDNY: Room 480, 500 Pearl Street, NY NY 10007
E-mail:
[email protected] - Tel: 718-716-3540
Regular Mail: Dag Hammarskjold Center, Box 20047, New York, NY 10017
DOJ-OGR-00006704