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Case 22-1426, Document Tacaa | 3475900, Page48 of 208 | A-44 2/22/23, 1:25 PM SDNY CM/ECF NextGen Version 1.6 no additional specific and supported application for relief. Nevertheless, the Court urges the MDC to consider whether sleep disruption for pretrial detainees can be reduced. The Court also admonishes the MDC and the Government to continue to ensure that Maxwell is subjected to only those security protocols that BOP determines are necessary for her safety and security, based upon neutral and applicable factors, and consistent with the treatment of similarly situated pre-trial detainees. The Government shall provide a copy of this Order to the Warden and General Counsel for the MDC. SO ORDERED. (Signed by Judge Alison J. Nathan on 5/14/2021) (Inl) (Entered: 05/14/2021) 05/14/2021 83 | 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 May 14, 2021 re: Proposed Redactions to Defendant's Letter re BSF Subpoena Document filed by USA. (Rohrbach, Andrew) (Entered: 05/14/2021) MEMO ENDORSEMENT as to Ghislaine Maxwell re: 278 Letter Proposed Redactions to Defendant's Supplemental Pre-Trial Motions... ENDORSEMENT: The Court grants in part the Government's redaction and sealing requests. Its 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). The Court concludes that these are judicial documents and that the First Amendment and common law presumptions of access attach. Id. at 11920. In balancing competing considerations against the presumption of access, the Court finds that the 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). Similarly, the Court concludes that the Government has shown that Exhibits E, F, G, H, and I should be filed under seal. With respect to Exhibit C, however, the Court concludes that narrowly tailored redactions are sufficient to advance the privacy interests the Government has identified. Accordingly, the Government is ORDERED to confer with defense counsel and submit proposed redactions to Exhibit C by May 20, 2021. SO ORDERED. (Signed by Judge Alison J. Nathan on 5/17/21)Gbo) (Entered: 05/17/2021) 05/20/2021 REPLY MEMORANDUM OF LAW in Support as to Ghislaine Maxwell re: 139 MOTION to Suppress Under the Fourth Amendment, Martindell, and the Fifth Amendment All Evidence Obtained from the Governments Subpoena to REDACTED and to Dismiss Counts Five And Six. . (Attachments: # 1 Exhibit J, #2 Exhibit K, #3 Exhibit L, #4 Exhibit M, #5 Exhibit N, # 6 Exhibit O, # 7 Exhibit P, # 8 Exhibit Q)(Everdell, Christian) (Entered: 05/20/2021) 05/20/2021 REPLY MEMORANDUM OF LAW in Support as to Ghislaine Maxwell re: 145 MOTION to Strike Surplusage from Superseding Indictment. . (Everdell, Christian) (Entered: 05/20/2021) 05/17/2021 28 WSs 05/20/2021 REPLY MEMORANDUM OF LAW in Support as to Ghislaine Maxwell re: 147 MOTION for Bill of Particulars and Pretrial Disclosures. . (Attachments: # 1 Exhibit A (Filed under seal))(Everdell, Christian) (Entered: 05/20/2021) 05/20/2021 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 May 20, 2021 re: Proposed Redactions to Exhibit C to Defendant's Supplemental Pre-Trial Motions Document filed by USA. (Pomerantz, Lara) (Entered: 05/20/2021) 05/21/2021 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Jeffrey S. Pagliuca dated May 21, 2021 re: Reply to Government Letter dated May 14 Regarding Proposed Redactions to Ms. Maxwells May 12, 2021 Letter (DE 283) (Pagliuca, Jeffrey) (Entered: 05/21/2021) https://ecf.nysd.uscourts.gov/cgi-bin/DktRpt.pl?211087015221896-L_1_0-1 44/113 DOJ-OGR-00020666