Case 1:15-cv-07433-LAP Document 139 Filed 05/04/16 Page 1 of 7 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF. REDACTED BRIEF IN SUPPORT OF THE PRIVILEGE CLAIMED FOR I I ER IN CAMERA SUBMISSION Plaintiff by and through her undersigned counsel, respectfully submits the following authority for the application of the privilege claimed regarding her in camera submission, pursuant to the Court's Order [DE 134] dated May 2, 2016) ARGUMENT Statements made by witnesses to law enforcement are protected by the public interest privilege, which "exists to encourage witnesses to come forward and provide information in criminal investigations ... without fear that the information will be disclosed." by v. City of New York, 201 A.D.2d 325, 326 (N.Y.A.D.,1994) (affirming the denial of a request for records held by the New York County District Attorney's office).2 Portions of this brief are redacted because they quote from, or describe, materials from in camera submission. The non-redacted brief will be submitted for in camera review because, if the relief requested is granted, will not have to disclose to Defendant the redacted portions of this Motion. 2 By the same principle, statements made by law enforcement to a witness that reference or reveal the witness's statements are similarly protected by the public interest privilege; otherwise, the protections for witness statements would be meaningless. Accordingly, communications by law enforcement to are privileged under the law enforcement privilege. EFTA02796765