DOJ-OGR-00006705.pdf

--- Page 1 --- The extracted text is: **Header:** Case 1:20-cr-00330-PAE Document 451 Filed 11/12/21 Page 2 of 5 **Main Body:** For further example, in Docket No. 387, all exhibits are withheld and the expected testimony of already anonymized Minor Victim-3 is redacted. In Docket No. 382, Exhibits A through D, F, H and I are all withheld in full, and large portions of even the table of contents are redacted. How is the public to access the basis for withholding, when even the titles / subjects are withheld? The First Amendment to the U.S. Constitution guarantees to the public a right of access to court proceedings. U.S. CONST. AMEND. I; Globe Newspaper Co. v. Superior Court, 457 U.S. 596, 603 (1982). The public's right of access is strongest when it comes to criminal proceedings such as these, which are matters of the "high[est] concern and importance to the people." Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 575 (1980) (plurality opinion). If deemed necessary, PLEASE TAKE NOTICE that Inner City Press and its undersigned reporter, in personal capacity, will move this Court before Honorable Alison J. Nathan, U.S. District Judge for the Southern District of New York, at a date and time directed by the Court, for entry of an order granting permission to the heard on unsealing the improperly redacted submission in this case, on public access to trial exhibits and to the provision of access, during COVID-19 and beyond, by listen-only audio line. Non-parties such as Inner City Press and myself have standing to intervene in criminal proceedings to assert the public's right of access. United States v. Aref, 533 F.3d 72, 81 (2d Cir. 2008). Please confirm receipt and docket this timely responsive filing, making Inner City Press an Interested Party, and thank you for your attention to it as you make logistical arrangements for the trial. Respectfully submitted, Matthew Russell Lee Inner City Press cc: Alison.Moe@usdoj.gov, maureen.comey@usdoj.gov, bc@sternheimlaw.com, bcsternheim@mac.com, ceverdell@cohengresser.com