617 [DOJ-OGR-00009537—DOJ-OGR-00009539]

Case 1:20-cr-00330-PAE Document617_ Filed 02/24/22 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 January 13, 2022 By Email 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, 82 20 Cr. 330 (AJN) Dear Judge Nathan: Counsel for Juror 50 has filed a motion to intervene, and to obtain a copy of certain materials relating to jury selection. The motion was submitted by email to Chambers. In an Order dated January 12, 2022, the Court directed the parties “to submit via email any proposed redactions on or before January 13, 2022, justifying any such request by reference to the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006).” The Government respectfully submits that no redactions are necessary, and accordingly the motion should be publicly filed. The defendant opposes any public filing of Juror 50’s motion, arguing that it is not a judicial document. This argument is meritless. Juror 50’s motion to intervene is quite obviously “relevant to the performance of a judicial function and useful in the judicial process.” United States DOJ-OGR- 00009537