DOJ-OGR-00019579.pdf

Case 1:20-cr-00330-AJN Document 208 Filed 08/24/20 Page 6 of 6 The Honorable Alison J. Nathan August 24, 2020 Page 6 documents, that is, documents that are 'relevant to the performance of the judicial function and useful in the judicial process.'" Kerik, 2014 WL 12710346, at *1 (S.D.N.Y. July 23, 2014), (quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995)). The Materials that Ms. Maxwell seeks to disclose (to judicial officers under seal) are, without question, judicial documents. And, at a minimum, Ms. Maxwell's opponent in the Civil Litigation knows both that the Government obtained an ex parte order to subpoena the information and what was produced. Accordingly, the argument that somehow grand jury secrecy will be compromised by disclosure, under seal to judicial officers reviewing the very material at issue, is absurd. Ms. Maxwell has demonstrated good cause for her very limited request to present a discrete set of sealed materials under seal to The government has not articulated a cogent reason for that information to be kept from the other judicial officers. Sincerely, Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) App.120 DOJ-OGR-00019579