U.S. Department of Justice

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 December 16, 2020 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: Pursuant to the Court's December 7, 2020 Order (Dkt. 89), the Government respectfully submits under seal an unredacted version of its memorandum of law and two accompanying exhibits in opposition to the defendant's renewed motion for bail. Additionally, the Government respectfully submits proposed redactions to its memorandum of law. Consistent with the redactions contained in the defense motion, the Government's proposed redactions are narrowly tailored to cover (1) information implicating the privacy interests of third parties previously articulated by the defense (Dkt. 86), and (2) Confidential Material produced by the Government in discovery and governed by paragraph 15 of the Protective Order in this case (Dkt. 36). Respectfully submitted, AUDREY.STRAUSS By:1M- Assistant United States Attorneys Southern District of New York Tel: Cc: All Counsel of Record (By email) EFTA00083710