DOJ-OGR-00006025.pdf

--- Page 1 --- **Case 1:20-cr-00330-PAE** **Document 399** **Filed 10/29/21** **Page 3 of 4** **Page 3** Exclude GX-52 should be filed under seal because it contains phone numbers, addresses, email addresses and other personally identifying information that must be sealed. 5. The defense's proposed redactions to Ms. Maxwell's Motion to Preclude Government Exhibits 251, 288, 294, 313 and 606 are necessary to protect privacy interests of third parties who are not currently parties or witnesses to the case and because the defense has objected to the admission of this evidence. If the evidence is made public before the Court determines its admissibility, it would be extremely prejudicial to Ms. Maxwell's ability to receive a fair trial (the defense will provide the proposed redactions to the Court under seal). 6. The defense agrees with the government that Exhibit A to Ms. Maxwell's Motion to Preclude Government Exhibits 251, 288, 294, 313 and 606 should be filed under seal for the same reasons. 7. The defense's proposed redactions to the Government's Omnibus Memorandum in Opposition are necessary for the same reasons (the defense will provide the proposed redactions to the Court under seal). **DOJ-OGR-00006025**