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Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page28 of 91

04/15/2021
202
MOTION to Continue Trial Date. Document filed by Ghislaine Maxwell. (Sternheim,
Bobbi) (Entered: 04/15/2021)

04/16/2021
203
ORDER as to Ghislaine Maxwell: The Court is in receipt of the parties' joint letter
responding to the Court's March 29, 2021 Order. The parties agree that the redactions
to pages 118 and 119 are no longer necessary. The Defendant continues to press for
the redactions on pages 129134. However, for the reasons stated in the Court's March
29, 2021 Order, the information is already part of the public record in this case and
accordingly the proposed redactions are unnecessary and overbroad. Dkt. No. 189; see
also United States v. Nejad, No. 18-CR-224 (AJN), 2021 WL 681427, at *11
(S.D.N.Y. Feb. 22, 2021). For the reasons stated in the Court's March 18, 2021 and
March 29, 2021 Orders, the Court approves the limited redactions to Exhibit 11 to the
Government's brief, except for the language quoted in the Indictment, which is already
part of the public record. The Government is therefore ORDERED to docket its
omnibus memorandum of law, along with the corresponding exhibits, by 3:00 p.m.
today, consistent with the Court's orders regarding redactions. The parties are further
ORDERED to docket their April 1, 2021 joint letter; if either side believes that
portions of that letter should be redacted, they shall propose redactions by April 19,
2021. (Signed by Judge Alison J. Nathan on 4/16/2021) (ap) (Entered: 04/16/2021)

04/16/2021
204
MEMORANDUM in Opposition by USA as to Ghislaine Maxwell re 139 MOTION to
Suppress Under the Fourth Amendment, Martindell, and the Fifth Amendment All
Evidence Obtained from the Governments Subpoena to REDACTED and to Dismiss
Counts Five And Six., 123 MOTION to Dismiss Counts One through Four of the
Superseding Indictment for Lack of Specificity., 135 MOTION to Dismiss Counts Five
and Six of the Superseding Indictment Because the Alleged Misstatements are Not
Perjurious as a Matter of Law., 121 MOTION to Dismiss Either Count One Or Count
Three of the Superseding Indictment as Multiplicitous., 125 MOTION to Dismiss the
Superseding Indictment as it was Obtained in Violation of the Sixth Amendment., 147
MOTION for Bill of Particulars and Pretrial Disclosures., 119 MOTION for Separate
Trial on Counts Ghislaine Maxwell (1) Count 5s-6s,5-6 ., 133 MOTION to Suppress
Under the Due Process Clause All Evidence Obtained from the Governments
Subpoena to REDACTED and to Dismiss Counts Five and Six., 145 MOTION to
Strike Surplusage from Superseding Indictment., 143 MOTION to Dismiss Counts
One Through Four of the Superseding Indictment as Time-Barred., 137 MOTION to
Dismiss Counts One Through Six of the Superseding Indictment for Pre-Indictment
Delay., 141 MOTION to Dismiss the Superseding Indictment for Breach of
Non-Prosecution Agreement.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit
3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit
9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12)(Pomerantz, Lara) (Entered:
04/16/2021)

04/16/2021
205
ORDER as to Ghislaine Maxwell: On March 15, 2021, the Defendant filed under seal
her reply briefs to the Government memorandum of law opposing Defendants' twelve
pre-trial motions. She filed the briefs, along with the corresponding exhibits,
temporarily under seal in order to permit the Government and the Court to review
certain proposed redactions. Of the twelve reply briefs, Reply Briefs 2, 4, 7, 8, 9, 11,
and 12 did not contain any redaction or sealing requests. Reply Briefs 1, 3, 5, 6, and 10
contain limited proposed redactions. Reply Briefs 3, 6, and 10 also contain exhibits
that the Defendant proposes be filed under seal. As set forth in the Defendant's cover
letter, the premise of the proposed redactions is that the materials were produced in
discovery and subject to the protective order that has been entered in this case. The
mere existence of a confidentiality agreement or a protective order covering judicial
documents is insufficient to overcome the presumption of access. See Aioi Nissay
Dowa Ins. Co. v. Prosight Specialty Mgmt. Co., Inc., 12-cv-3274 (JPO), 2012 WL
3583176, at *6 (S.D.N.Y. Aug. 21, 2012). And the Court did not receive specific
requests or justifications to redact or seal any of the materials. The Defendant is
ORDERED to docket Reply Briefs 2, 4, 7, 8, 9, 11, and 12 on ECF today, as she did
not propose any redactions to these and the Government has not voiced any opposition
to these being filed without redactions. If either side is seeking these or any other
redactions to the remaining reply briefs, they must file a letter indicating the redactions
they request and providing specific justifications for the sealing requests or redactions,
in line with the principles set forth in Lugosch. By April 20, 2021, the parties shall
confer and submit a letter informing the Court whether any redactions are being
sought. If no redactions are being sought, the Defendant is ORDERED to docket the

DOJ-OGR-00020414