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Case 1:20-cr-00330-AJN Document 53 Filed 09/08/20 Page 1 of 3 My) Haddon, Morgan and Foreman, p.c Jeffrey Pagliuca HADDON pene aceite 150 East 10th Avenue FOREMAN Denver, Colorado 80203 PH 303.831.7364 Fx 303.832.2628 www.hmflaw.com jpaglisca@hmflaw.com August 24, 2020 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Proposed Redactions to Request to Modify Protective Order (Under Seal) United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, In accordance with this Court’s Order of August 18, 2020 (Doc. 44), Ms. Maxwell hereby respectfully submits under seal her proposed redactions to her Request to Modify Protective Order (“Request”), filed under seal on August 17, 2020. Ms. Maxwell also has filed her Reply under seal and contemporaneously submits her proposed redactions to that pleading.! Ms. Maxwell has no opposition to keeping under seal, and redacting from her Request and Reply, the contents, description and discussion of the sealed materials themselves; because the government has marked them Confidential, the Protective Order requires as much. See Doc. 36, 7 15. The government’s proposed redactions, however, go further and propose to redact yy . The government would have this Court redact on the premise that it would “risk jeopardizing the government’s investigation.” ! To the extent this Court believes this letter also should be filed publicly, counsel also has indicated her proposed redactions to this letter. DOJ-OGR-00001760