DOJ-OGR-00019574.jpg

Case PACE ONBSOANENt DocORehi2L 0 Fed S908 Ragehagel HS 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: Reply in Support of Request to Modify Protective Order (Under Seal)! United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, Defendant Ghislaine Maxwell filed a simple request: that she be permitted to disclose under seal to (the “Civil EE Litigation”) the fact that her adversary i already handed over ee Hl. to the U.S. Attorney’s Office pursuant to a subpoena 9 ee The government proposes to keep J in the dark about the fact and method of the disclosure. They claim the civil litigation 1s “unrelated,” that issuance of the subpoena was “standard practice,” and that disclosure will jeopardize an ongoing criminal investigation and “permit dissemination of a vast swath of materials.” Each of the government’s arguments lack merit. The Civil Litigation First, the government claims the civil action is Resp. at 1. The assertion is fivo10U. ' Ms. Maxwell has filed a letter motion which seeks leave to file this reply under seal, while providing the unredacted version to the government and the Court. This reply describes and discusses sealed materials and materials subject to the Protective Order in this case. Ms. Maxwell also simultaneously files under separate cover her proposed redactions to her Request to Modify Protective Order (Aug. 17, 2020), and this Reply, in accordance with the Court’s Order of August 18, 2020 (Doc. 44). App.115 DOJ-OGR-00019574