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Case 1:20-cr-00330-PAE Document534 Filed 12/09/21 Page1lof2
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
December 9, 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 seeks redactions to its letter motion for admission of
Government Exhibit 52 (Dkt. No. 533), sealing of Exhibit A to that letter, and redactions to Exhibit
B to that letter. 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 letter and exhibits are judicial documents subject to the
common law presumption of access, the limited proposed redactions and sealing are narrowly
tailored to protect the privacy interests of the Minor Victims and witnesses, including individuals
who are subjects of the Court’s pseudonym order, as well as third parties. The Government also
notes that the redactions to Exhibit B conform to redactions of that document in Giuffre v. Maxwell,
15 Civ. 7433 (LAP).
DOJ-OGR- 00008301