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Case 1:20-cr-00330-AJN Document 128 Filed 01/28/21 Page 2 of 2 Honorable Alison J. Nathan January 28, 2021 Page 2 meaning of the Protective Order in this case, and relate to third-party privacy interests or materials that remain sealed in the civil proceeding. e The proposed redactions to the defendant’s motion for a bill of particulars and pretrial disclosures (Motion 10) protect the privacy interests of victim-witnesses and protect the integrity of the Government’s ongoing investigation. e The proposed redactions to the defendant’s motion to suppress under the Fourth and Fifth Amendments (Motion 11) are narrowly tailored to protect the integrity of the Government’s ongoing investigation. In addition, the Government has no objection to the defendant’s proposed redactions to her motion to suppress under the Due Process Clause (Motion 3) as the proposed redactions are narrowly tailored to protect the Government’s ongoing investigation. The Government respectfully submits that a limited number of additional redactions would be appropriate with respect to Motion 3 in order to be consistent with the other redactions proposed by the defendant in that particular motion. The Government will submit those additional proposed redactions under seal by email. Respectfully submitted, AUDREY STRAUSS United States Attorney By: ___s/ Maurene Comey / Alison Moe / Lara Pomerantz / Andrew Rohrbach Assistant United States Attorneys Southern District of New York Tel: (212) 637-2324 Ce: All counsel of record, by email DOJ-OGR- 00002336