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Case 1:20-cr-00330-PAE Document 451 Filed 11/12/21 Page4of5 most of Pages 3 and 4 redacted. In both Dkt 446 and 447, redactions proliferate and Exhibit A is withheld in full. This is unacceptable. Again, Inner City Press understands that the listen-only call-in telephone lines available so far in the case, there may be an attempt to discontinue them. The Court should take judicial notice of continuing COVID-19 issues, including people's understandable concerns about congregating even in so-called overflow rooms. Be aware that the District for the District of Columbia still allows public phone access to all criminal proceedings, even those held in-person. That should happen here; we note that this Court itself continues to offer listen-only audio access in other criminal cases before it. Why not this one? The loss of First Amendment freedoms, even for a short period of time, unquestionably constitutes irreparable injury. E/rod v. Burns, 427 U.S. 347, 373 (1976). And as to trial exhibits, see for example Judge Jed S. Rakoff's order in US v. Weigand, 20-cr-188 (JSR) https://www.documentcloud.org/documents/20536946- rakofforderonmrlicp There, Judge Rakoff ordered the US Attorney's Office to make trial exhibit available to the public at large. While this was done, belatedly, in US v. Parnas, it was refused in the current US v. Cole. It cannot be refused in this case. The First Amendment to the U.S. Constitution guarantees to the public a right of access to court proceedings. U.S. CONST. AMEND. I; Globe Newspaper Co. v. Superior Court, 457 U.S. 596, 603 (1982). The public’s right of access is strongest when it comes to criminal proceedings such as these, which are matters of the “high[est] concern and importance to the people.” Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 575 (1980) (plurality opinion). If deemed necessary, PLEASE TAKE NOTICE that Inner City Press and its undersigned reporter, in personal capacity, will move this Court before Honorable Alison J. Nathan, U.S. District Judge for the Southern District of New York, at a date and time directed by the Court, for entry of an order granting permission to the heard on unsealing the improperly redacted submission in this case, on public access to trial exhibits and to the provision of access, during COVID-19 and beyond, by listen-only audio line. DOJ-OGR-00006707