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Case 1:20-cr-00330-PAE Document 284 Filed 05/17/21 Page2of2 Page 2 The Government respectfully submits that Exhibits C, E, F, G, H, and I should be filed entirely under seal in order to protect the privacy interests of victims and third parties implicated in the documents. The Court has accepted similar exhibits under seal in this case to protect such privacy interests. (See, e.g., Dkt. No. 168, 232). 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 Ce: Deft | (By ECF a Delense counsel (By ) The Court grants in part the Government’s redaction and sealing 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). The Court concludes that these are judicial documents and that the First Amendment and common law presumptions of access attach. /d. at 119-20. In balancing competing considerations against the presumption of access, the Court finds that the 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). Similarly, the Court concludes that the Government has shown that Exhibits E, F, G, H, and I should be filed under seal. 5/17/21 MMe Quisor With respect to Exhibit C, however, the Court concludes that narrowly tailored redactions are sufficient to advance the privacy interests the Government has identified. Accordingly, the Government is ORDERED to confer with defense counsel and submit proposed redactions to Exhibit C by May 20, 2021. SO ORDERED. ALISON J. NATHAN, U.S.D_J. SO ORDERED. DOJ-OGR-00004135