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Case 1:20-cr-00330-PAE Document 332 Filed 09/01/21 Page2of3 Page 2 interests of the victims who provided those materials to their attorneys, the victims who are depicted in those photographs, the third parties who are referenced in the journal entries, and the third parties who are depicted in those photographs. The Government does not seek any redactions of Exhibit 2 to the Motion. With respect to Exhibits 3 and 4 to the Motion, the Government respectfully submits that limited redactions are appropriate to protect the privacy interests of victims who have not identified themselves on the record in this case and of third parties referenced in the Motion. Simultaneously with the filing of this letter, the Government is submitting to the Court under seal its proposed redactions to the Motion, Exhibit 1, Exhibit 3, and Exhibit 4. The Government’s 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 Motion and Exhibits are judicial documents subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims—including two victims who have not identified themselves on the record in this case and who have not publicly identified themselves as victims referenced in the Indictment in this case—and third parties referenced in the documents. The Court has accepted other filings under seal or in redacted form in this case to protect such privacy interests. (See, e.g., Dkt. No. 168, 232, 284, 290). The Government notes that it does not seek to redact the names and identifying information of individuals who have previously been mentioned by name without redaction in public filings in this case. Rather, the Government only seeks to redact the names and identifying information of victims and third parties who have not previously been referenced in public filings in this case. Similarly, the Government seeks to redact photographs and documents that have not previously been filed publicly in this case and which constitute the personal property of victims and third DOJ-OGR-00005025