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Case 1:20-cr-00330-AJN Document 87 Filed 12/04/20 Page 3 of 4 The Honorable Alison J. Nathan November 30, 2020 Page 3 disclosure of even the smallest personal detail about anyone connected to Ms. Maxwell— whether or not they are named or anonymized—will ignite a frenzy of media speculation seekin to identify them. To name just one example We have every reason to expect that the same will occur with anyone even obliquely mentioned in connection with the Motion. Accordingly, the reference in the second sentence to the reference in the third sentence to We do not make this request for redaction lightly. We are acutely mindful that courts are generally reluctant to seal anything in a court filing beyond what is required by statute or local court rules. We are therefore proposing targeted redactions, consistent with the case law in this Circuit, that are no more extensive than necessary to protect these third parties. See Lugosch v. Pyramid Co. of Onandaga, 435 F.3d 110, 124 (2d Cir. 2006); see also Unites States v. Wey, 256 F. Supp. 3d 355, 411 (S.D.N.Y. 2017) (Nathan, J.) (granting motion to seal evidentiary exhibits on privacy grounds). Ultimately, we seek the same privacy protections for these people that the government has sought and obtained for Ms. Maxwell’s accusers and for other information covered by the Protective Order in this case. By making this request for redaction, we are not trying to litigate this case in secret. We are merely seeking the ability to file a renewed bail application for Ms. Maxwell without further risking the safety and privacy of sureties needed to support that application. This is the first of several confidentiality issues that will arise in connection with the Motion, and the sureties will be looking at the Court’s ruling as an indication of the level of confidentiality they can expect to be afforded. These individuals have requested that their privacy and safety be appropriately protected by the Court. For the reasons set forth above, we respectfully request that the Court file the proposed redacted version of the November 25" Letter, attached as Exhibit A, and the proposed redacted version of this letter, attached as Exhibit B. In the alternative, we request leave to withdraw both letters and refile the November 25" Letter with the redacted sentences deleted. DOJ-OGR-00001857