DOJ Letter: Southern D.New, October 18, 2021, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN (EFTA00105946)

U.S. Department of Justice United States Attorney Southern District of New York The Silvio!. Mollo Building One Saint Andrew's Plaza New York, New York 10007 October 18, 2021 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 (MN) Dear Judge Nathan: The Government respectfully submits its motions in limine, which the Government is submitting to the Court under seal by email with proposed redactions. The Government's proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Although the Government's motions in limine are judicial documents subject to the common law presumption of access, the proposed redactions are narrowly tailored to protect the privacy interests of victims-including victims who have