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Case 1:20-cr-00330-PAE Document506- Filed 11/24/21 Pagelof2
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
November 24, 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:
Pursuant to the Court’s Order at Dkt. No. 495, the Government submits proposed
redactions to the filings associated with the Government’s motion to preclude six defense experts.
In addition to the proposed redactions, the Government respectfully seeks to redact Government
Exhibit A, the defense expert notice, which the Government has filed on the docket with the same
redactions (see Dkt. No. 424-1), and moves to file Government Exhibit B under seal. The
Government’s proposed redactions and sealing 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 parties’ briefing and the Court’s Opinion & Order are judicial documents subject to
the common law presumption of access, the limited proposed redactions are narrowly tailored to
protect the privacy interests of the Minor Victims, including a Minor Victim who is a subject of
the Court’s pseudonym order.
The defense has informed the Government that it is not seeking any additional redactions.
DOJ-OGR-00008040