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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