DOJ-OGR-00002780.jpg

Case 1:20-cr-00330-PAE Document 170 Filed 03/22/21 Page 2 of 2
Page 2

that is contained in the publicly-filed Indictment in this case. In particular, the additional redactions proposed by the defense to pages 129 to 134 on March 9, 2021 relate to language that is contained in Count Six of the publicly filed Indictment in this case. Although the Government respectfully submits that there is no basis under the applicable standard to redact language that is already publicly available on the docket in this case, the Government is prepared to file the brief with redactions consistent with the Order subject to any further direction from the Court. In addition, the defense also requested earlier today an additional redaction to the bottom of page 134, which is reflected in a red box in the enclosed memorandum. The language covered by this additional redaction is also related to information that is in the publicly filed Indictment. Although, as noted above, the Government is aware of no basis to redact language that is available in the publicly-docketed Indictment, the Government is prepared to file the brief with this additional redaction, subject to any further direction from the Court.

The Government respectfully submits under seal the enclosed version of its memorandum of law with proposed redactions consistent with the Court’s Order, the redactions originally proposed by the Government and contained on pages 118 to 119, and the additional redaction proposed by the defendant on page 134. The Government will publicly file its memorandum of law with the enclosed proposed redactions, unless modified by the Court, at the Court’s direction.

Respectfully submitted,

AUDREY STRAUSS
United States Attorney

By: s/
Maurene Comey / Alison Moe /
Lara Pomerantz / Andrew Rohrbach
Assistant United States Attorneys

Cc: All Counsel of Record (By email)

DOJ-OGR-00002780