U.S Department of Justice United States Attorney Southern District of New York Th Sihlo Mollo Building One Saint Andrews Plaza New York New York April BY ECF The Honorable Alison Nathan United States District Court Southern District of New York United States Courthouse Foley Square New York New York Re United States Ghislaine Maxwell Cr AJN Dear Judge Nathan The Government respectfully submits this letter in response to the Courts Order dated April which directed the Government to submit any requests for redaction of information contained in filings regarding the defenses proposed Rule subpoena Dkt No After reviewing the relevant filings the Government seeks a limited number of redactions which are narrowly tailored to protect the privacy interests of third parties In particular the Government respectfully requests that the Court permit the redaction of the names and identifying information of particular third parties referenced in the defenses response to the objections of Boies Schiller Flexner LLP BSF to the defenses proposed Rule subpoena BSFs reply and the April joint letter addressing the redactions to those same documents Today the Government is submitting to the Court by email its proposed redactions to those documents which the Government respectfully requests be filed under seal These proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch Pyramid Co of Onondaga F.3d 2d Cir Although these documents are judicial documents that are subject to the common law presumption of access the Page proposed redactions are narrowly tailored to protect the privacy interests of third parties referenced in the documents These redactions are thus consistent with similar tailored redactions permitted by the Court in this case to protect the privacy interests of third parties Accordingly the Government respectfully requests that the Court adopt the proposed redactions The Government has conferred with defense counsel and counsel from BSF both of whom indicated that they take no position on the Governments redaction requests Respectfully submitted AUDREY STRAUSS United States Attorney By Assistant United States Attorneys Southern District of New York Cc All Counsel of Record By ECF
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