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Case 1:20-cr-00330-PAE Document 232 Filed 04/22/21 Page4of4 Page 4 accept Exhibit A to Reply Brief 1 and Exhibit A to Reply Brief 10 under seal. 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 Cc: All Counsel of Record (By email) The Court grants the Government’s proposed redaction and sealing requests. This 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). Under this test, the Court must: (i) determine whether the documents in question are “judicial documents;” (ii) assess the weight of the common law presumption of access to the materials; and (iii) balance competing considerations against the presumption of access. /d. at 119-20. The Court concludes that these are judicial documents and that the First Amendment and common law presumptions of access attach. In balancing competing considerations against the presumption of access, however, the Court finds that the specific 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). The Government’s letter does not discuss Exhibit L of Reply Brief 6. By April 23, 2021, the parties shall either propose redactions to Exhibit L of Reply Brief 6, which was originally filed under seal, or they shall indicate to the Court that they seek no redactions and file it on ECF. SO ORDERED. 4/22/21 MMe Quaisir SO ORDERED. ALISON J. NATHAN, U.S.D,]. DOJ-OGR- 00003934