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Castate20:20-G0SMBBAAIN DinonurTtiSo0 Flei@20k/22 Rtapeclofa 11 The Honorable Alison J. Nathan February 1, 2022 Page 9 (S.D.N.Y. Sept. 30, 2020); Kemp v. Noeth, No. 20-CV-9121 (RA)(SN), 2021 WL 1512712, at *2 (S.D.N.Y. Apr. 15, 2021).? Finally, it is important to emphasize that Ms. Maxwell does not seek to seal the Motion indefinitely. She seeks only a temporary sealing to protect the integrity of any fact-finding process ordered by the Court. In this case, the pretrial motions remained under seal for several weeks before they were filed on the docket in redacted form. That limited delay did not have a meaningful impact on the public’s right of access or the press’ ability to report on this case. So too here. Indeed, it could potentially take less time for the Court to rule on the Motion or for a hearing to be completed. Conclusion For the foregoing reasons, the Court should order that the Motion remain temporarily sealed until the Court rules on Ms. Maxwell’s Motion or until the conclusion of any hearing ordered by the Court. The Court should further order the government to file its response under seal so that the defense can assert its position regarding sealing. 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) 3 Moreover, even if the defense attempted to make redactions, most of the Motion would remain under seal. The limited portion that could potentially be unsealed would be entirely divorced from context and would not provide the public with any useful information, nor would it allow the press to perform its role of monitoring the federal courts. 2087306.1 DOJ-OGR- 00008908