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Case 1:20-cr-00330-PAE Document 488 Filed 11/22/21 Page1of6 ° U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007 November 18, 2021 BY E-MAIL The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 82 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter regarding birth certificates that are marked as Government Exhibits for trial.! By way of background, the Government has obtained and produced to the defense certified copies of the birth certificates for each of the Minor Victims. (See GX-11-16). Although the Government has asked the defense to stipulate to the authenticity of these records, and although the defense has identified no reason to doubt the authenticity of these records, the defense has not agreed to a stipulation. Accordingly, the Government seeks the relief in the instant motion, to which it is entitled under the law, and to avoid calling records custodians from five state agencies with custody over the birth certificates. ' The Government moves to file a redacted version this letter motion. The 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 this letter motion is a judicial document subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims, including victims who have not been publicly identified, and who are a subject of the Court’s order granting the motion to let certain victims and witnesses testify under pseudonyms, and third parties. * The Government is coordinating with Department of Justice Office of International Affairs to further establish the predicates for self-authentication of Witness-3’s birth certificate and will make the appropriate motion when it is ripe. See Fed. R. Evid. 902(3). DOJ-OGR-00007401