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Case 1:20-cr-00330-PAE Document 451 Filed 11/12/21 Page3of5 Inner City Press November 12, 2021 By E-mail Hon. Alison J. Nathan, United States District Judge Southern District of New York, 40 Foley Square, New York, NY 10007 Re: US v. Maxwell, 20-cr-330 (AJN), second timely opposition to sealing and withholding portions of motions in limine, trial exhibits, public access, docketing Dear Judge Nathan: On behalf of Inner City Press and in my personal capacity, I have been covering the above-captioned case. This concerns today's flurry of motions in limine, still replete with redactions. This is a Press request that the filings be further unsealed consistent with Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) and other applicable case law. This is a request that this opposition to sealing be docketed as, for example, took place in US v. Avenatti, 19-cr-374 (JMF), Dkt 85, see https://storage.courtlistener.com/recap/gov.uscourts.nysd.516151/gov.uscourts.nys d.516151.85.0.pdf The Government's Justifications for redaction (Docket No. 399, docketed at 10:06 pm on Friday Oct 29) cites Lugosch then says "The Government also seeks sealing of trial exhibits, which are not public." Inner City Press immediately opposed this. While as one example within the US motions of limine, the Government has now redacted the title of its Argument X, footnote 13 and many other phrases are still redacted, as are significant portions of its Exhibit A. Dkt 438 and 438-1. Worse, the Defendant's response to the US motions in limine has large portions of its table of contents redacted (for example Argument I, A 1, 2 and 3; C 1 and 2, and D). A full sentence argument in Defendant's submission opposing Doctor Rocchio, who testified earlier this week, is still redacted, see Dkt 443, FNS. In Dkt 444 on Page 4, a full paragraph about what the Government has represented that a witness is expected to testify to - and the entirety of Exhibits A and B are still withheld. The same is true of Dkt 445 - both exhibits withheld, and Inner City Press: In-house SDNY: Room 480, 500 Pearl Street, NY NY 10007 E-mail: Matthew.Lee@innercitypress.com - Tel: 718-716-3540 Regular Mail: Dag Hammarskjold Center, Box 20047, New York, NY 10017 DOJ-OGR-00006706