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Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page32 of 91 the grounds that it was returned by a grand jury sitting at the White Plains courthouse (Dkt. No. 125) is DENIED as moot. SO ORDERED. (Signed by Judge Alison J. Nathan on 4/21/21)(jbo) (Entered: 04/21/2021) 04/21/2021 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated April 21, 2021 re: Proposed Pretrial Schedule Document filed by USA. (Comey, Maurene) (Entered: 04/21/2021) 04/21/2021 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated April 21, 2021 re: Proposed Pretrial Schedule (Everdell, Christian) (Entered: 04/21/2021) 04/21/2021 ORDER as to Ghislaine Maxwell: The Court will schedule a trial date for the severed perjury counts after trial of the non—perjury counts is completed. Given that and in light of the representations in the Government's April 21, 2021 letter, see Dkt. No. 227, the Court intends to defer resolution of the pending motions to suppress (including resolution of the request for an evidentiary hearing) until after the trial on the non-perjury counts. If either side objects, counsel shall state the basis for any objection by letter on or before by 5pm on Thursday, April 22, 2021.SO0 ORDERED. (Signed by Judge Alison J. Nathan on 4/21/2021) (Inl) (Entered: 04/22/2021) 04/22/2021 MEMO ENDORSEMENT as to Ghislaine Maxwell on 222 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated April 20, 2021 re: Redactions to Defense Reply Briefs and Exhibits. ENDORSEMENT: The Court grants the Government's proposed redaction and sealing requests. This conclusion is guided by the three—part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (1) determine whether the documents in question are "judicial documents;" (ii) assess the weight of the common law presumption of access to the materials; and (iii) balance competing considerations against the presumption of access. Id. at 11920. The Court concludes that these are judicial documents and that the First Amendment and common law presumptions of access attach. In balancing competing considerations against the presumption of access, however, the Court finds that the specific arguments the Government has put forward in this letter, including the need to protect the privacy interests of third parties and alleged victims, favor the narrowly tailored redactions. See United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995). The Government's letter does not discuss Exhibit L of Reply Brief 6. By April 23, 2021, the parties shall either propose redactions to Exhibit L of Reply Brief 6, which was originally filed under seal, or they shall indicate to the Court that they seek no redactions and file it on ECF. SO ORDERED. (Signed by Judge Alison J. Nathan on 4/22/2021) (Inl) (Entered: 04/22/2021) 04/22/2021 LETTER by Boies Schiller Flexner LLP as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Sigrid McCawley dated 04-22-2021 re: Request to Bring Electronic Devices Document filed by Boies Schiller Flexner LLP. (Attachments: # 1 Exhibit Electronic Device Form)(McCawley, Sigrid) (Entered: 04/22/2021) 04/22/2021 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca dated April 22, 2021 re: Response to Dkt. No. 227, Governments April 21, 2021 Letter re Ms. Maxwells Motions to Suppress (Pagliuca, Jeffrey) (Entered: 04/22/2021) 04/22/2021 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated April 22, 2021 re: Response to Defense Request for Adjournment Document filed by USA. (Comey, Maurene) (Entered: 04/22/2021) 04/22/2021 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated April 22, 2021 re: Response to the Court's April 22, 2021 Order Document filed by USA. (Pomerantz, Lara) (Entered: 04/22/2021) MEMO ENDORSEMENT as to Ghislaine Maxwell on 233 LETTER by Boies Schiller Flexner LLP as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from Sigrid McCawley dated 04-22-2021 re: Request to Bring Electronic Devices Document. 04/22/2021 INO ao ~~] DOJ-OGR- 00020418