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Case 1:20-cr-00330-AJN Document 81 Filed 12/03/20 Page 2 of 2 The proposed redactions satisfy this test. First, the Court finds that the Defendant’s letter motions are “relevant to the performance of the judicial function and useful in the judicial process,” thereby qualifying as a “judicial document” for purposes of the first element of the Lugosch test. United States v. Amodeo (“Amodeo I’), 44 F.3d 141, 145 (2d Cir. 1995). And while the Court assumes that the common law presumption of access attaches, in balancing competing considerations against the presumption of access, the Court finds that the arguments the Defendant has put forth—including, most notably, the privacy interests of the individuals referenced in the letters—favor her proposed and tailored redactions. The Defendant is hereby ORDERED to docket the redacted versions of the two letters by December 4, 2020. For the reasons outlined in the Government’s letter dated December 2, 2020, Dkt. No. 80, the Court DENIES the Defendant’s request for an in camera conference. In order to protect the privacy interests referenced in the Defendant’s November 25, 2020 letter, the Court will permit the Defendant to make her submission in writing and to propose narrowly tailored redactions. The parties are hereby ORDERED to meet and confer and to jointly prepare a briefing schedule for the Defendant’s forthcoming renewed motion for release on bail. SO ORDERED. MM. 0, iste Dated: December 3, 2020 New York, New York ALISON J. NATHAN United States District Judge DOJ-OGR-00001848