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Case 1:20-cr-00330-PAE Document 222 Filed 04/20/21 Page2of4 Page 2 The Government respectfully submits that the proposed redactions are consistent with the redactions ordered by the Court on March 18, 2021 as “the interest in protecting the safety and privacy of those individuals outweigh the presumption of access that attaches” to the document. (Dkt. 168 at 3); see also United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) (holding that the privacy interests of third parties “should weigh heavily in a court’s balancing equation”). The defense has indicated that it has no objection to removing the redactions it had originally proposed on page 3. As to the remaining proposed redactions, the Government respectfully requests that the Court adopt the remaining proposed redactions, which are narrowly tailored to cover the privacy interests of third parties. The defense takes no position on the remaining proposed redactions. As to the exhibits to Reply Brief 3, the defense submitted Exhibits M and N under seal. The Government does not object to the public filing of Exhibits M and N, but respectfully submits that the names, email addresses, and other contact information of third parties should be redacted from Exhibits M and N to protect the privacy interests of third parties. The defense has indicated that it agrees that email addresses and other contact information for third parties should be redacted pursuant to the Court’s local rules. The Government respectfully submits under seal proposed redactions to Exhibits M and N for the Court’s consideration. The defense also submitted Exhibits J and O to Reply Brief 3 under seal. The Government filed Exhibits 5 and 7 to its Omnibus Memorandum of Law in Opposition to the Defendant’s Pretrial Motions, which are, respectively, redacted versions of Exhibits J and O. See Dkt. 204. The Government had set forth proposed redactions to Exhibits 5 and 7 in order to protect the privacy interests of third parties (Dkt. 162), which the Court adopted on March 18, 2021 (see Dkt. 168 at 2-3). Accordingly, the Government respectfully submits that the defense should redact DOJ-OGR-00003871