DOJ-OGR-00020566.jpg

Case 22-1426, Document 3-2, 07/08/2022, 3344434, Page80 of 92 01/26/2022 | 585 | ORDER as to Ghislaine Maxwell. The Court is in receipt of Defendant's motion for a new trial and accompanying exhibits, which she requests to file under seal. See Dkt. No. 580. The Court has also received requests from media organizations to unseal the motion. The Court is aware there is substantial public interest in this matter and will ensure that the First Amendment right to public access is fully safeguarded. At the same time, the Court must act deliberately and hear from the parties in considering these sealing issues in order to ensure the integrity of any potential inquiry process going forward, should one be ordered. That too is in the public, as well as the Defendant's and the Government's, interest. Accordingly, to the extent the Defense requests that arguments in favor of sealing should themselves be sealed, that request is DENIED. Arguments in favor of sealing can be made in such a way so as not to undermine the grounds for seeking sealing or redaction in the first instance. The Defense is therefore ORDERED to file a letter on the public docket on or before February 1, 2022, that justifies the proposed sealing by reference to the three—part test in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). The Government may file on ECF a response to the Defenses justification letter on or before February 4, 2022. The Government's opposition to the Defenses new trial motion is due February 2, 2022. Dkt. No. 571. Per the established practice in this case, the Government must provide a copy via email to the Defense to allow the Defense the opportunity to propose narrowly tailored redactions and/or sealing. If either party proposes redactions to or sealing of the Government's anticipated opposition, a letter justifying such redactions or sealing must be filed on the public docket. The Defense letter must be filed on or before February 8, 2022, and the Government letter must be filed by February 11, 2022. The same process will apply for any Defense reply in support, which is due February 9, 2022. Dkt. No. 571. If redactions or sealing are proposed, the Defense letter justifying such requests would be due February 15, 2022, and the Government letter would be due February 18, 2022. The parties are FURTHER ORDERED to address the New York Times Company's motion to unseal the filled—out questionnaires for the twelve seated jurors. See Dkt. No. 583. Letters by both parties must be submitted via ECF on or before February 11, 2022. SO ORDERED (Signed by Judge Alison J. Nathan on 1/26/2022)(jw) (Entered: 01/26/2022) 01/26/2022 LETTER addressed to Judge Alison J. Nathan from Matthew A. Leish dated 1/26/2022 re: I write on behalf of Daily News, L.P. (jw) (Entered: 01/26/2022) 01/27/2022 LETTER addressed to Judge Alison J. Nathan from Nathan Siegel dated 1/26/2022 re: Letter addressed to Judge Alison J. Nathan on behalf of American Broadcasting Companies, Inc and NBC Universal News Group (jw) (Entered: 01/27/2022) 01/28/2022 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 January 28, 2022 re: Redaction of Witness Name Document filed by USA. (Pomerantz, Lara) (Entered: 01/28/2022) 01/28/2022 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated 1/28/22 re: Redaction (Everdell, Christian) (Entered: 01/28/2022) 02/01/2022 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated 2/1/22 re: Sealing Motion for New Trial (Everdell, Christian) (Entered: 02/01/2022) 02/01/2022 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated 2/1/22 re: Extension of Time (Everdell, Christian) (Entered: 02/01/2022) 02/02/2022 MEMO ENDORSEMENT as to Ghislaine Maxwell on re: 591 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Christian R. Everdell dated 2/1/22 re: Extension of Time. ENDORSEMENT: The extension request is hereby GRANTED. The briefing schedule for other post—verdict motions is revised as follows: — Defense submission: February 11, 2022. Government response: February 25, 2022. Defense reply: March 11, 2022. (Motions due by 2/11/2022. Responses due by 2/25/2022. Replies due by 3/11/2022) (Signed by Judge Alison J. Nathan on 2/2/2022) (ap) (Entered: 02/02/2022) 02/04/2022 Sal 1S) ORDER as to Ghislaine Maxwell: As a post-trial house—keeping matter, attached to this Order are the Court Exhibits. The parties have proposed redactions to several DOJ-OGR- 00020566