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Case 1:20-cr-00330-PAE Document 241 Filed 04/23/21 Page2of2 Page 2 proposed redactions are narrowly tailored to protect the privacy interests of third parties referenced in the documents. These redactions are thus consistent with similar, tailored redactions permitted by the Court in this case to protect the privacy interests of third parties. Accordingly, the Government respectfully requests that the Court adopt the proposed redactions. The Government has conferred with defense counsel and counsel from BSF, both of whom indicated that they take no position on the Government’s redaction requests. Cc: All Counsel of Record (By ECF) 4/23/21 a SO ORDERED. ALISON J. NATHAN, U.S.D,J. Respectfully submitted, AUDREY STRAUSS United States Attorney Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York 212-637-2324 The Court grants the Government’s redaction 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). Under this test, the Court must: (i) determine whether the documents in question are “judicial documents;” (11) assess the weight of the common law presumption of access to the materials; and (iii) balance competing considerations against the presumption of access. Jd. at 119-20. The Court concludes that these are judicial documents and that the First Amendment and common law presumptions of access attach. But in balancing competing considerations against the presumption of access, 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 referenced in the documents, favor the narrowly tailored redactions. See United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995). The Defendant and Boies Schiller are hereby ORDERED to docket the respective documents with the Government's proposed redactions by April 23, 2021. SO ORDERED. DOJ-OGR- 00003964