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Case 1:20-cr-00330-AJN Document 32 Filed 07/27/20 Page 1of1
op een U.S. Department of Justice
‘Set 4 United States Attorney
Southern District of New York
The Silvio J. Mollo Building Ff ——
One Saint Andrew’s Plaza USDC SDNY
New York, New York 10007 :
DOCUMENT
ELECTRONICALLY FILED
July 27, 2020 DOC #:
VIA ECF DATE FILED:7/27/2020
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)
The Government's response to the Defense's letter is due by 5 SO ORDERED. 7/27/20
p-m. on July 28, 2020. The Defense may file a reply by 5 p.m.
on July 29, 2020. Before the Government's response is filed, .
the parties must meet and confer by phone regarding this issue, \ vie
and any response from the Government must contain an ‘
affirmation that the parties have done so. Alisca J. Wathen. USL
SO ORDERED. ,
DOJ-OGR-00001663