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Case 1:20-cr-00330-AJN Document 87 Filed 12/04/20 Page 1 of 4 800 Third Avenue New York, NY 10022 COHEN & GRESSER LLP +1 212.957 7600 phone www.cohengresser.com Mark S. Cohen Christian R. Everdell +1 (212) 957-7600 mcohen@cohengresser.com ceverdell@cohengresser.com November 30, 2020 TO BE FILED UNDER SEAL VIA EMAIL (SUBMITTED PURSUANT TO SECTION 2(B) OF JUDGE NATHAN’S INDIVIDUAL PRACTICES IN CRIMINAL CASES) The Honorable Alison J. Nathan United States District Court Southern District of New York AO Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we respectfully submit this letter in response to the Court’s order, dated November 25, 2020, directing Ms. Maxwell to justify why her letter of the same date requesting an in camera conference to discuss confidentiality concerns related to her Renewed Motion for Release on Bail (the “Motion”) should be sealed or redacted. We continue to believe that sealing the November 25, 2020 letter (the “November 25" Letter’) in its entirety is warranted and appropriate under the governing case law. However, in response to the Court’s order, we ask the Court to file a redacted version of the November 25 Letter, attached hereto as Exhibit A, which redacts only the information necessary to protect third parties from threats and harassment. In addition, because this letter must make reference to the same confidential information contained in the November 25" Letter in order to justify the proposed redactions, we further ask the Court to file a redacted version of this letter, attached as Exhibit B. If the Court is not inclined to allow any of these redactions, we request leave to withdraw both letters and refile the November 25" Letter with the redacted sentences deleted. Every submission related to the Motion, including this letter, presents the defense with a Catch-22. To support Ms. Maxwell’s position regarding sealing and confidentiality, we are asked to provide the Court with specific information about the people supporting Ms. Maxwell’s bail application and the need for sealing. But until we know what confidentiality protections the Court is willing to put in place, we are obligated to protect these people from the potentially devastating consequences of being publicly identified by divulging as little information about them as possible. We therefore continue to believe that an in camera conference, attended by all counsel, is the best way to address all of the confidentiality issues related to the Motion. DOJ-OGR-00001855