DOJ-OGR-00008963.jpg

Case 1:20-cr-00330-PAE Document 603 Filed 02/16/22 Page1of3 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 February 16, 2022 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: By letter dated February 16, 2022, the defendant proposed redactions to the parties’ briefing regarding Juror 50. (Dkt. No. 602). The Government respectfully submits this letter in response to the defendant’s proposed redactions, which are overbroad and inconsistent with both the public’s right of access to judicial documents and the Court’s February 11, 2021 Order, which permitted redactions of three narrow categories: (1) the questions the parties propose be asked at any hearing, (2) specific factual information developed by the parties which is not public, and (3) redactions to protect juror anonymity and privacy. (Dkt. No. 596 at 4). The categories of redactions proposed by the defendant are impermissibly broad. In particular: e The defendant seeks to redact discussion of the substance of Juror 50’s questionnaire. For the reasons set forth in the Government’s February 4, 2021 and February 11, 2021 letters (Dkt. Nos. 594, 598), the Government respectfully submits that Juror 50’s questionnaire should be made public, along with all other questionnaires of the twelve seated jurors in this case. Indeed, the defendant has not opposed the New York Times Company’s motion DOJ-OGR-00008963