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Case 1:20-cr-00330-PAE Document 284 Filed 05/17/21 Pagelof2 aN U.S. Department of Justice United States Attorney luspe SDNY Southern District of Nev| DOCUMENT ELECTRONICALLY FILED The Silvio J. Mollo Building pac #: One Saint Andrew's Plaza New York, New York 10007 DATE FILED: 5/17/21 May 12, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court’s Order dated May 10, 2021, which directed the Government to propose and justify any requests for redaction of the defendant’s memorandum in support of her supplemental pre-trial motions and exhibits. (Dkt. No. 274). After reviewing the defense’s memorandum, the Government seeks a limited number of redactions. These proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the defense’s memorandum in support of her supplemental pre-trial motions is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims and third parties referenced in the document. These redactions are thus consistent with similar, tailored redactions permitted by the Court in this case to protect the privacy interests of third parties. (See, e.g., Dkt. No. 168, 232). Today the Government is submitting to the Court by email its proposed redactions to the defense’s memorandum, which the Government respectfully requests be filed under seal. DOJ-OGR-00004134