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566 KB

Extraction Summary

2
People
4
Organizations
2
Locations
1
Events
2
Relationships
3
Quotes

Document Information

Type: Legal correspondence / court filing
File Size: 566 KB
Summary

A letter from the U.S. Attorney's Office to Judge Alison J. Nathan regarding the case *United States v. Ghislaine Maxwell*. The Government is submitting motions *in limine* under seal, requesting redactions to protect the privacy of victims and third parties, and specifically requesting that 'Section X' remain redacted until the conclusion of the trial.

People (2)

Name Role Context
Alison J. Nathan Judge
Recipient of the letter; Presiding Judge over United States v. Ghislaine Maxwell.
Ghislaine Maxwell Defendant
Subject of the criminal case (20 Cr. 330) referenced in the letter.

Organizations (4)

Name Type Context
U.S. Department of Justice
Sender organization
United States Attorney Southern District of New York
Prosecuting office sending the letter
United States District Court Southern District of New York
Court where the case is being heard
Second Circuit
Appellate court referenced regarding legal precedent (Lugosch v. Pyramid Co. of Onondaga)

Timeline (1 events)

2021-10-18
Government submits motions in limine under seal.
Southern District of New York
U.S. Government Judge Alison J. Nathan

Locations (2)

Location Context
Office address of the US Attorney
Address of the Court/Judge Nathan

Relationships (2)

United States Adversarial (Legal) Ghislaine Maxwell
Case caption: United States v. Ghislaine Maxwell
Judge presiding over Maxwell's case

Key Quotes (3)

"The Government respectfully submits its motions in limine, which the Government is submitting to the Court under seal by email with proposed redactions."
Source
DOJ-OGR-00005264.jpg
Quote #1
"the proposed redactions are narrowly tailored to protect the privacy interests of victims—including victims who have not identified themselves on the record in this case"
Source
DOJ-OGR-00005264.jpg
Quote #2
"In addition, the Government seeks redaction of Section X at least until the conclusion of trial."
Source
DOJ-OGR-00005264.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,498 characters)

Case 1:20-cr-00330-PAE Document 359 Filed 10/18/21 Page 1 of 2
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. 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 (AJN)
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 not identified themselves on the record in this case and who have not publicly identified
themselves as victims referenced in the Indictment in this case—and third parties referenced in the
document.
In addition, the Government seeks redaction of Section X at least until the conclusion of
trial. Additional justification for this sealing request is located in footnote 11 on page 49 of the
Government’s motions in limine.
DOJ-OGR-00005264

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