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

1 ype, Ione ley SON U.S. Department of Justice

QQ vere’ AY al 950 Pennsylvania Avenue NW Washington, D.C. 20530

September 13, 2024 By ECF The Honorable Dale E. Ho United States District Judge U.S. District Court for the Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, New York 10007 Re: — United States v. M/Y Amadea, No. 23-cv-9304 (DEH) Dear Judge Ho: We write respectfully on behalf of the Government to request the Court’s leave to file the Government’s Motion to Compel and Preclude Regarding Depositions In A Foreign Country partially and supporting exhibit under seal. The Government requests to file the motion and exhibit partially under seal for reasons similar to those for which other recent filings regarding foreign depositions have been made under seal. Namely, disclosing the identity of the country may undermine efforts to obtain approval of the deposition in that country and may also disclose sensitive information regarding the United States’ relations with that government. The Government will file a partially redacted version on the Court’s public docket. Respectfully submitted, GRANTED. The presumption of public access documents is overcome here, and redaction is DAMIAN WILLIAMS based on the the Government's representation . . United States Attorney it is necessary to protect foreign relations. Cf. Halpern Southern District of New York No. 94 Civ. 365, 2002 WL 31012157, at *7 D.N.Y. Aug. 31, 2001) (redactions proper under FOIA to tect “relations between the United States and a foreign By: /s/Jennifer Jude __ JENNIFER JUDE DOMINIKA TARCZYNSKA of the Court is respectfully directed to place ECF Assistant United States Attorney 240 under seal, and to close ECF No. 239. MARGARET A. MOESER mant's shall respond to the issues raised in the Chief letter motion, see ECF No. 241, in a letter not Money Laundering and Asset Recovery three (3) pages, by September 18, 2024. Section, Criminal Division U.S. Department of Justice

E. HO Tr nti de OO nwt enelke nce TL

By: /s/ D. Hunter Smith JOSHUA L. SOHN D. HUNTER SMITH Trial Attorney 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)