Haddon, Morgan and Foreman. P.c

Haddon, Morgan and Foreman. P.c Jeffrey Paglluca II A D D O N M OR G A N FOREMAN 303.832.2628 August 24, 2020 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York Re: Reply in Support of Request to Modify Protective Order (Under Seal)i United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Defendant Ghislaine Maxwell filed a simple request: that she be permitted to disclose under seal to the Second Circuit Court of Appeals and a separate district court in this same court (the "Civil Litigation") the fact that her adversary in the civil case pending in those two fora already handed over nearly 90,000 pages of "confidential" protective-order materials, much of it also filed under seal, to the U.S. Attorney's Office pursuant to a subpoena while those two courts have sub judice whether to unseal many of the very same materials. The government proposes to keep both courts in the dark about the fact and method