Epstein Secrets

of their testimony. ' 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 this letter is a judicial document subject to the common law presumption of access, the proposed redactions

hose individuals. (See Gov't Mot. in Limine, Dkt. No. 380, at 16 n.7 (making this request)); see May 6, 2019 Text Order, Raniere, 18 Cr. 204 (NGG) (E.D.N.Y.) ("Sketch artists .. . may not draw exact likenesses of jurors or witnesses other than co-defendants should they testify . ."). It would defeat the

Exhibit B, which is Dr. Hall's evaluation of Minor Victim-4, in accordance 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 this brief and the attached exhibit are judicial documents subject to the common law presumption of access,

the defense to provide forthwith. Dated: November 15, 2021 New York, New York Respectfully submitted, DAMIAN WILLIAMS United States Attorney for the Southern District of New York By: /s/ Assistant United States Attorneys 26 EFTA00024981

dential with the Court, it was to additionally file a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. Id. ¶ 10. Absent consent of the producing party, designated documents "shall not ... be disclosed."3 Id. 115 . WESTLAW 2018 Thomson Reuters. No c

s." 191 1101 1111Whether discovery or trial, "a court must first conclude that the documents at issue are indeed `judicial documents.' " Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119 (2d Cir. WESTLAW © 2018 Thomson Reuters. No claim to original U.S. Government Works. 21 EFTA00020561 --- PAGE BREAK --- v. M