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799 KB
Extraction Summary
2
People
3
Organizations
2
Locations
3
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
799 KB
Summary
This legal document is a letter dated November 30, 2020, to Judge Alison J. Nathan, requesting permission to file a redacted bail application for Ms. Maxwell. The author argues that redactions are necessary to protect the privacy and safety of third parties, such as financial sureties, from the intense media speculation that would follow any disclosure of their identities. The letter cites legal precedent and the privacy protections previously afforded to Ms. Maxwell's accusers as justification for the request.
People (2)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
Recipient of the letter, mentioned as the judge in the case and in a case citation (Nathan, J.).
|
| Ms. Maxwell | Subject of legal proceedings |
The individual for whom a renewed bail application is being filed and whose connections the letter seeks to protect v...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Pyramid Co. of Onandaga | company |
Mentioned in a case citation: Lugosch v. Pyramid Co. of Onandaga.
|
| The Court | government agency |
The judicial body being requested to file a redacted letter and rule on confidentiality.
|
| the government | government agency |
Mentioned as having previously sought and obtained privacy protections for Ms. Maxwell's accusers.
|
Timeline (3 events)
2020-11-30
A request was made to the Court to file redacted versions of letters related to a bail application for Ms. Maxwell.
Ms. Maxwell's legal counsel
The Honorable Alison J. Nathan
The letter discusses the intent to file a 'renewed bail application for Ms. Maxwell'.
Ms. Maxwell
sureties
Relationships (2)
The document mentions the need to protect the 'safety and privacy of sureties needed to support that application' (the bail application for Ms. Maxwell).
The document contrasts the privacy protections sought for Ms. Maxwell's supporters with those already obtained by the government for her accusers.
Key Quotes (2)
"disclosure of even the smallest personal detail about anyone connected to Ms. Maxwell— whether or not they are named or anonymized—will ignite a frenzy of media speculation seeking to identify them."Source
— Author of the letter (Ms. Maxwell's counsel)
(Justification for the request to redact information about third parties connected to Ms. Maxwell's bail application.)
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Quote #1
"Ultimately, we seek the same privacy protections for these people that the government has sought and obtained for Ms. Maxwell’s accusers and for other information covered by the Protective Order in this case."Source
— Author of the letter (Ms. Maxwell's counsel)
(Arguing for equal privacy protections for individuals supporting Ms. Maxwell as were given to her accusers.)
DOJ-OGR-00001857.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,408 characters)
Case 1:20-cr-00330-AJN Document 87 Filed 12/04/20 Page 3 of 4
The Honorable Alison J. Nathan
November 30, 2020
Page 3
November 30, 2020
Page 3
disclosure of even the smallest personal detail about anyone connected to Ms. Maxwell—
whether or not they are named or anonymized—will ignite a frenzy of media speculation seeking
to identify them. To name just one example, [REDACTED]
whether or not they are named or anonymized—will ignite a frenzy of media speculation seeking
to identify them. To name just one example, [REDACTED]
We have every reason to expect that the same will occur with
anyone even obliquely mentioned in connection with the Motion.
anyone even obliquely mentioned in connection with the Motion.
Accordingly, the reference in the second sentence to [REDACTED]
Similarly, the reference in the third sentence to [REDACTED]
We do not make this request for redaction lightly. We are acutely mindful that courts are
generally reluctant to seal anything in a court filing beyond what is required by statute or local
court rules. We are therefore proposing targeted redactions, consistent with the case law in this
Circuit, that are no more extensive than necessary to protect these third parties. See Lugosch v.
Pyramid Co. of Onandaga, 435 F.3d 110, 124 (2d Cir. 2006); see also Unites States v. Wey, 256
F. Supp. 3d 355, 411 (S.D.N.Y. 2017) (Nathan, J.) (granting motion to seal evidentiary exhibits
on privacy grounds). Ultimately, we seek the same privacy protections for these people that the
government has sought and obtained for Ms. Maxwell’s accusers and for other information
covered by the Protective Order in this case.
generally reluctant to seal anything in a court filing beyond what is required by statute or local
court rules. We are therefore proposing targeted redactions, consistent with the case law in this
Circuit, that are no more extensive than necessary to protect these third parties. See Lugosch v.
Pyramid Co. of Onandaga, 435 F.3d 110, 124 (2d Cir. 2006); see also Unites States v. Wey, 256
F. Supp. 3d 355, 411 (S.D.N.Y. 2017) (Nathan, J.) (granting motion to seal evidentiary exhibits
on privacy grounds). Ultimately, we seek the same privacy protections for these people that the
government has sought and obtained for Ms. Maxwell’s accusers and for other information
covered by the Protective Order in this case.
By making this request for redaction, we are not trying to litigate this case in secret. We
are merely seeking the ability to file a renewed bail application for Ms. Maxwell without further
risking the safety and privacy of sureties needed to support that application. This is the first of
several confidentiality issues that will arise in connection with the Motion, and the sureties will
be looking at the Court’s ruling as an indication of the level of confidentiality they can expect to
be afforded. These individuals have requested that their privacy and safety be appropriately
protected by the Court.
are merely seeking the ability to file a renewed bail application for Ms. Maxwell without further
risking the safety and privacy of sureties needed to support that application. This is the first of
several confidentiality issues that will arise in connection with the Motion, and the sureties will
be looking at the Court’s ruling as an indication of the level of confidentiality they can expect to
be afforded. These individuals have requested that their privacy and safety be appropriately
protected by the Court.
For the reasons set forth above, we respectfully request that the Court file the proposed
redacted version of the November 25th Letter, attached as Exhibit A, and the proposed redacted
version of this letter, attached as Exhibit B. In the alternative, we request leave to withdraw both
letters and refile the November 25th Letter with the redacted sentences deleted.
redacted version of the November 25th Letter, attached as Exhibit A, and the proposed redacted
version of this letter, attached as Exhibit B. In the alternative, we request leave to withdraw both
letters and refile the November 25th Letter with the redacted sentences deleted.
DOJ-OGR-00001857
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