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Case 1:20-cr-00330-PAE Document 323 Filed 08/19/21 Page2of2 The Honorable Alison J. Nathan August 19, 2021 Page 2 The exhibits to the motion also attach documents that were obtained independent of the criminal discovery. We submit that it is the government’s burden to justify any redactions to these documents under Lugosch.! Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 ce: All Counsel of Record (By ECF) ' Page 20 of Exhibit 1 to the motion appears to contain personal email addresses of one of the accusers and another person. The defense has no objection to redacting these email addresses. DOJ-OGR-00005006