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Case 1:20-cr-00330-PAE Document 603 Filed 02/16/22 Page1of3
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
February 16, 2022
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:
By letter dated February 16, 2022, the defendant proposed redactions to the parties’
briefing regarding Juror 50. (Dkt. No. 602). The Government respectfully submits this letter in
response to the defendant’s proposed redactions, which are overbroad and inconsistent with both
the public’s right of access to judicial documents and the Court’s February 11, 2021 Order, which
permitted redactions of three narrow categories: (1) the questions the parties propose be asked at
any hearing, (2) specific factual information developed by the parties which is not public, and (3)
redactions to protect juror anonymity and privacy. (Dkt. No. 596 at 4).
The categories of redactions proposed by the defendant are impermissibly broad. In
particular:
e The defendant seeks to redact discussion of the substance of Juror 50’s questionnaire. For
the reasons set forth in the Government’s February 4, 2021 and February 11, 2021 letters
(Dkt. Nos. 594, 598), the Government respectfully submits that Juror 50’s questionnaire
should be made public, along with all other questionnaires of the twelve seated jurors in
this case. Indeed, the defendant has not opposed the New York Times Company’s motion
DOJ-OGR-00008963