United States v. The M/Y Amadea, a Motor Yacht Bearing International Maritime Organization No. 1012531, Including All Fixtures, Fittings, Manuals, Stocks, Stores, Inventories, and Each Lifeboat, Tender, and Other Appu

Opinion

(Ue (eos OR g [oy ee U.S. Department of Justice

A See sos Ap Sse “ie 950 Pennsylvania Avenue NW Washington, D.C. 20530 September 27, 2024 VIA CM/ECF Hon. Dale E. Ho U.S. District Judge U.S. District Court for the Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. M/Y Amadea, No. 23-cv-9304 (DEH) Dear Judge Ho, The Government respectfully submits this letter motion requesting permanent sealing of its forthcoming Opposition Brief to a witness’s motion to quash deposition subpoena. While the Government’s Opposition Brief will not list witness names, it will provide enough identifying details that a knowledgeable third-party might be able to infer the identities of two witnesses in this case. The Court has expressed a willingness to shield witness identity in this case, particularly when witnesses express concern for their livelihood or safety if their identities were made public. See, e.g., ECF Nos. 122, 227. Accordingly, the Government requests that its forthcoming Opposition Brief be permanently sealed to protect the identities of the two witnesses discussed therein. GRANTED. The presumption of public access to documents is overcome here. See Walker v. Respectfully Submitted, York, No. 15 Civ. 500, 2017 WL 2799159, at *6 Y. June 27, 2017) (witness safety is "a higher value” redaction). DAMIAN WILLIAMS of the Court is respectfully directed to place ECF No. United States Attorney Southern District of New York seal, and to close ECF No. 267. USD f Justi .». Department of Justice By: /s/ Jennifer Jude A JENNIFER JUDE HO DOMINIKA TARCZYNSKA District Judge Assistant U.S. Attorneys 30, 2024 Southern District of New York New York

MARGARET A. MOESER Acting Chief Money Laundering and Asset Recovery Section, Criminal Division U.S. Department of Justice

By: /s/ Joshua L. Sohn JOSHUA L. SOHN D. HUNTER SMITH Trial Attorneys Money Laundering and Asset Recovery Section

JENNIFER KENNEDY GELLIE Executive Deputy Chief Counterintelligence and Export Control Section, National Security Division U.S. Department of Justice

By: /s/ Yifei Zheng YIFEI ZHENG Trial Attorney Counterintelligence and Export Control Section

cc: Claimants’ counsel (by ECF)