U.S. Department of Justice United States Attorney Southern District of New York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 March 22, 2021 BY ECF & ELECTRONIC MAIL 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: In accordance with the Court's March 18, 2021 order (the "Order"), the parties have met and conferred regarding proposed redactions to Exhibit 11 and the defendant's cover letter dated March 9, 2021. The parties have reached an agreement regarding redactions as to Exhibit 11 and the defendant's cover letter. The Government intends to file its omnibus memorandum of law and the corresponding exhibits consistent with the Court's Order, with one exception to which the defense consents. In particular, the defense has indicated that it no longer wishes the Government to remove the redactions the Government had originally proposed to pages 118 to 119 of the Government's brief. Those redactions refer to and quote portions of an exhibit filed under seal by the defense and which the Government understands is filed under seal in v. Maxwell, 15 Civ. 7433 (LAP). Accordingly, the Government has kept those redactions in the attached omnibus memorandum of law. Additionally, the Government wishes to note that some portions of the defense's proposed redactions, which the Court adopted in the Order, would redact language that is contained in the publicly-filed Indictment in this case. In particular, the additional redactions proposed by the defendant to pages 129 to 134 on March 9, 2021 relate to language that is quoted in Count Six of the publicly filed Indictment in this case. Although the Government sees no basis under the prevailing case law to redact language that is already publicly available on the docket in this case, t