Case 1:20-cr-00330-PAE Document589_ Filed 01/28/22 Page1of3
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Christian R. Everdell
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January 25, 2022
BY EMAIL
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell, 82 20 Cr. 330 (AJN)
Dear Judge Nathan:
We write in response to the Court’s email yesterday, January 24, 2022, requesting that the
parties submit a revised copy of Court Exhibit 2 with Carolyn Andriano’s last name redacted. For
the reasons set forth below, the defense believes that Ms. Andriano’s last name should not be
redacted in the publicly filed version of Court Exhibit 2.
The redactions to Court Exhibit 2 were the subject of some discussion among the parties.
The government originally proposed that Court Exhibit 2 should be filed under seal because the
list of names is alphabetized and redacting only anonymized names would provide identifying
information for anonymized witnesses. The defense objected to that proposal on the grounds that
it was unnecessary and overbroad to seal the entire document and that the names of anonymized
witnesses could be redacted.
The defense further objected to Ms. Andriano’s name being redacted in any way due to her
recent post-trial interview with the Daily Mail, in which she publicly disclosed her full name and
declared her intention to waive her right to anonymity. According to the article, Ms. Andriano
stated the following:
2086175.1
DOJ-OGR-00008849