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Case PACE ONBSOuANENt DocOmeA Ae 0 Fuad S908 Rag ehagenk 3 The Honorable Alison J. Nathan August 24, 2020 Page 2 Moreover, the government has made repeated, highly public statements, including at the press conference following Ms. Maxwell’s indictment,’ in the press conference following Mr. Epstein’s indictment,’ in a press conference convened at the doorstep of Mr. Epstein’s former New York mansion,’ and in other publicly-released statements® that its investigation into associates of Mr. Epstein is ongoing and active. . The process to evaluate whether a judicial document should remain under seal is clear. Once a determination is made that the materials are judicial documents the Court is required to determine whether any countervailing interests outweigh the presumptive right to public access. Brown v. Maxwell, 929 F.3d 41, 49-50 (2d Cir. 2019). Frankly, Ms. Maxwell does not believe that the government has established a countervailing interest compelling enough to justify continued sealing of the documents. It is also likely that these same documents OCC will be the subject of future motion practice in this Court, x However, Ms. Maxwell has no interest in additional pretrial publicity related to any of these documents and submits that protecting her right to a fair trial is the countervailing interest that, at this point, requires her proposed redactions and the continued sealing of the materials with the exception of her limited request to file the materials under scal > “These charges to be announced today, are the latest result of our investigation into Epstein, and the people around him who facilitated his abuse of minor victims. That investigation remains ongoing.” (https://www rev.con/blog/transcripts/announcement-transcript-of-charges-against-ghislaine-maxwell-in-new-york- jeffrey-epstein-associate-arrested). 3 “This in no way is over, OK. There's going to be more investigative steps they're going to take place and the FBI with the U.S. attorney here is going to continue to investigate.” http://transcripts.cnn.com/TRANSCRIPTS/1907/08/ath.01 html). * Sarah Nathan and Kate Sheey, “Prince Andrew refuses to cooperate with feds in Jeffrey Epstein probe,” NY Post (Jan. 27, 2020) (https://nypost.com/2020/01/27/prince-andrew-refuses-to-cooperate-with-feds-in-jeffrey-epstein- probe/). 5 Alan Feuer, “Prince Andrew and U.S> Prosecutor in Nasty Dispute Over Epstein Case,” NY Times (June 8, 2020) (https://www nytimes.com/2020/06/08/nyregion/jeffrey-epstein-prince-andrew html). App.113 DOJ-OGR-00019572