EFTA00027704 - EFTA00027705
This is a cover letter from the U.S. Attorney's Office for the Southern District of New York, dated October 18, 2021, requesting permission to file motions in limine with redactions in the criminal case against Ghislaine Maxwell.
This brief procedural document is a formal letter from prosecutor Damian Williams to Judge Alison J. Nathan regarding the Ghislaine Maxwell criminal trial (Case 20 Cr. 330). The prosecution seeks court permission to publicly file their pre-trial motions in limine with proposed redactions to protect the privacy of victims and third parties. The redactions are justified under the Second Circuit's test from Lugosch v. Pyramid Co., and notably, the prosecution requests that Section X remain sealed at least until the trial concludes, with additional justification provided in a footnote on page 49 of the actual motions document.
Key Highlights
- •Procedural filing in United States v. Ghislaine Maxwell requesting redactions to protect victim privacy
- •References victims who have not publicly identified themselves in connection with the indictment
- •Requests special sealing of Section X until conclusion of trial, with justification in footnote 11
- •Prosecutor Damian Williams handling the high-profile Maxwell case before Judge Alison J. Nathan
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Bates Range
EFTA00027704 - EFTA00027705
Pages
2
Document Content
Page 1 - EFTA00027704
U.S. Department of Justice United States Attorney Southern District of New York The SiAdol 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 (MN) 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. EFTA00027704
Page 2 - EFTA00027705
Page 2 Accordingly, the Government respectfully requests that the Court permit the Government to publicly file its motions in limine with its proposed redactions. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Assistant United States Attorneys Southern District of New York Cc: Defense counsel (By ECF) EFTA00027705
Entities Mentioned
Alison J. Nathan
PERSON • 2 mentions
Damian Williams
PERSON
Ghislaine Maxwell
PERSON • 3 mentions
British socialite and sex trafficker, daughter of Robert Maxwell, accomplice of Jeffrey Epstein
Lugosch
PERSON
Prince Andrew
PERSON
Third child of Queen Elizabeth II and Prince Philip, Duke of Edinburgh (born 1960)
Pyramid Co. of Onondaga
ORGANIZATION
Second Circuit
ORGANIZATION
Statistics
Pages:2
Entities:7
Avg. OCR:0.9%
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