Caaask:2C20O0030330304BN UThoniunterttZ743 FIThtert1016O732131 Patel aid 1 GRESSER LLP Christian It Everdell +I (212) 95".- 600 reverdelleirobtogresser.com USDC SDNY DOCU ELECTRONICALLY FILED DOC DATE FILED; 5/10 _ 1 800 Thad Avenue New York. NY 10022 +1 212 957 7600 photo vnwo COMMTOSSOI COrn May 7, 2021 The Government is hereby ORDERED to propose and justify any redactions by May 12, 2021. SO ORDERED. VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, New York 10007 Re: United States it Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we will be filing our Omnibus Memorandum in Support of Ms. Maxwell's Supplemental Pretrial Motions Relating to the S2 Superseding Indictment with accompanying exhibits. The memorandum and exhibits contain Confidential Information produced in discovery that is governed by paragraph 15 of the Protective Order (Dkt. 36). Accordingly, pursuant to our prior practice, we will not file the supplemental motions on the public docket until we are instructed to do so by the Court. Instead, we will submit the supplemental motions by email to the Court and the government under seal—pursuant to Rule 2(B) of the Court's individual rules of criminal practice—to give the government the opportunity to propose and justify any redactions it deems necessary. Please contact us with any questions. Your consideration is greatly appreciated. Respectfully submitted, /s/ Christian R. Everdell Christian R. Everdell & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: All counsel of record (via email) EFTA02831949