DOJ-OGR-00001316.pdf

Case 21-770, Document 38, 04/12/2021, 3075291, Page2 of 3 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT ---------------------------------------------------- x UNITED STATES OF AMERICA, Appellee, : AFFIRMATION - v. - : Docket Nos. 21-58, 21- GHISLAINE MAXWELL, : 770 Defendant-Appellant, : ---------------------------------------------------- x STATE OF NEW YORK ) COUNTY OF NEW YORK ) ss.: SOUTHERN DISTRICT OF NEW YORK ) LARA POMERANTZ, pursuant to 28 U.S.C. § 1746, hereby affirms under penalty of perjury: 1. I am an Assistant United States Attorney in the Office of Audrey Strauss, United States Attorney for the Southern District of New York, and I represent the Government in this appeal. I submit this affirmation in support of the Government's motion to file an unredacted copy of Exhibit F, the Government's Memorandum in Opposition to the Defendant's Renewed Motion for Release, under seal. 2. Counsel for the Defendant-Appellant filed publicly a redacted version of Exhibit F, which was the version publicly filed on the docket in this case. (Dkt. No. 100). The redactions to that document are narrowly tailored to cover (1) information implicating the privacy interests of third parties previously articulated by the defense (Dkt. No. 86), and (2) Confidential Material produced by the Government in discovery and governed by the protective order in this case (Dkt. No. 36). The Government believes that some of the redacted information is pertinent to this appeal and therefore seeks leave to file an unredacted copy of Exhibit F under seal. DOJ-OGR-00001316