DOJ-OGR-00003872.jpg

Case 1:20-cr-00330-PAE Document 222 Filed 04/20/21 Page3of4 Page 3 Exhibits J and O to Reply Brief 3 to reflect the redactions approved by the Court and reflected in the publicly filed versions of Exhibits 5 and 7 to the Government’s opposition. The defense has indicated that it is prepared to follow those redactions. As to Reply Brief 6, the Government respectfully requests that the Court adopt the defense’s proposed redactions, which are narrowly tailored to cover information implicating the personal privacy interests of third parties. The proposed redactions are consistent with the proposed redactions requested by the Government on pages 158 to 159 and 163 of its opposition to the defendant’s pre-trial motions, which the Court granted on March 18, 2021. (Dkt. 168 at 1). The defense has indicated that it has no objection to removing the redactions and filing Reply Brief 6 on the public record. As to Reply Brief 10, the Government respectfully requests that the Court adopt the redactions originally proposed by the defense, which are narrowly tailored to cover information implicating the personal privacy interests of third parties and are consistent with prior redactions in earlier briefing. The Government respectfully submits that Exhibit A to Reply Brief 10 should be filed entirely under seal in order to protect the personal privacy interests of the third party implicated in the document. The defense has indicated that it has no objection to removing the redactions and filing the brief and Exhibit A on the public record. Accordingly, the Government respectfully requests that the Court adopt the redactions originally proposed by the defense to Reply Briefs 3, 6, and 10 and the redactions described above as to Exhibits J, M, N, and O to Reply Brief 3. The Government further requests that the Court DOJ-OGR- 00003872