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Case 22-1426, Document 1-2, 07/08/2022, 3344417, Page80 of 91

exhibits and the sealing of Court Exhibit 4. The Court concludes that the 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), and narrowly
tailored. The redactions serve the purpose of protecting the anonymity of jurors and of
victim-witnesses subject to the Court's anonymity order. With respect to Court Exhibit
4, rather than seal the entire document, the Court has redacted the information that
would potentially identify the victim-witness who testified pursuant to the Court's
anonymity order. Unredacted copies of the Court Exhibits will be filed under seal.
(Signed by Judge Alison J. Nathan on 2/4/2022)(ap) (Entered: 02/04/2022)

02/04/2022 594 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
AUSAs Maurene Comey, Alison Moe, Lara Pomerantz, and Andrew Rohrbach dated
February 4, 2022 re: Opposition to Defendant's Sealing Request Document filed by
USA. (Pomerantz, Lara) (Entered: 02/04/2022)

02/08/2022 595 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 2/8/2022 re: Request for Sealing (Sternheim, Bobbi) (Entered:
02/08/2022)

02/11/2022 596 ORDER as to Ghislaine Maxwell. The Court is in receipt of the parties' letters
addressing the Defendant's request to temporarily seal her motion for a new trial and
accompanying exhibits, and the Governments response in opposition and
accompanying exhibits. See Dkt. Nos. 590, 594, 595. Several media organizations
have also filed letters seeking unsealing. The Court is also in receipt of Juror 50's
motion to intervene. Both the Government and the Defendant oppose intervention. The
Defendant seeks to strike or, in the alternative, seal Juror 50's motion. For the reasons
outlined more fully below, the Court rules as follows. First, the Defendant's motion to
temporarily seal in their entirety all documents related to the motion for a new trial is
DENIED. Any sealing of judicial documents must be narrowly tailored to serve
competing interests. (Signed by Judge Alison J. Nathan on 2/11/22)(jw) (Entered:
02/11/2022)

02/11/2022 597 ORDER as to Ghislaine Maxwell. The Court's chambers received the attached letter
via email from counsel for the National Association of Criminal Defense Lawyers
(NACDL) seeking leave to file an amicus brief regarding the Defendant's motion for a
new trial. The Court issues this Order in response. If any party wishes to file an amicus
brief concerning the Defendant's motion for a new trial, it may submit to the Court via
email a motion for leave to do so on or before February 18, 2022. The Court will only
consider such a motion if: It is timely submitted by February 18, 2022; (Amicus Brief
due by 2/18/2022) (Signed by Judge Alison J. Nathan on 2/11/22)(jw) (Entered:
02/11/2022)

02/11/2022 598 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Alison Moe, Maurene Comey, Lara Pomerantz, and Andrew Rohrbach dated February
11, 2022 re: motion by the New York Times Company. Document filed by USA.
(Moe, Alison) (Entered: 02/11/2022)

02/11/2022 599 MOTION for New Trial to Obtain Relief Requested in Memorandum in Support of
Post-Trial Motions. Document filed by Ghislaine Maxwell. (Everdell, Christian)
(Entered: 02/11/2022)

02/11/2022 600 MEMORANDUM in Support by Ghislaine Maxwell re 599 MOTION for New Trial
to Obtain Relief Requested in Memorandum in Support of Post-Trial Motions..
OMNIBUS MEMORANDUM in Support by Ghislaine Maxwell re Post-Trial Motions
(Everdell, Christian) (Entered: 02/12/2022)

02/15/2022 601 SEALED DOCUMENT placed in vault. (jus) (Entered: 02/15/2022)

02/16/2022 602 LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan from Bobbi C.
Sternheim dated 02/16/2022 re: Letter in Response to Dkt. 596 (Sternheim, Bobbi)
(Entered: 02/16/2022)

02/16/2022 603 LETTER by USA as to Ghislaine Maxwell addressed to Judge Alison J. Nathan from
Alison Moe, Maurene Comey, Lara Pomerantz, and Andrew Rohrbach dated February
16, 2022 re: Letter regarding proposed redactions. Document filed by USA. (Moe,
Alison) (Entered: 02/16/2022)

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