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Case 1:20-cr-00330-AJN Document 31 Filed 07/27/20 Page 1 of 1
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
July 27, 2020
VIA 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 submits this letter to request the opportunity to respond to
defense counsel’s letter motion seeking the entry of a protective order, which was filed this
morning. The Government and defense counsel were in discussions — as recently as 6 p.m. last
night — in the hopes of jointly proposing a protective order. Until seeing the filing on ECF this
morning, the Government had understood those discussions to be ongoing. In light of the
defense’s letter, however, the Government respectfully requests until 5 p.m. tomorrow to submit a
response.
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
By: __/s
Alex Rossmiller / Alison Moe / Maurene Comey
Assistant United States Attorneys
Southern District of New York
Tel: (212) 637-2324
Ce: — All counsel of record (by ECF)
DOJ-OGR-00001662