{
  "document_metadata": {
    "page_number": "1",
    "document_number": "589",
    "date": "01/28/22",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 589 Filed 01/28/22 Page 1 of 3 COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com 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, S2 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",
  "text_blocks": [
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      "content": "Case 1:20-cr-00330-PAE Document 589 Filed 01/28/22 Page 1 of 3",
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    {
      "type": "printed",
      "content": "COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "January 25, 2022",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "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",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "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.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "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.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "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:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2086175.1 DOJ-OGR-00008849",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Christian R. Everdell",
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Carolyn Andriano"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "United States District Court",
      "Daily Mail"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "January 25, 2022",
      "January 24, 2022",
      "01/28/22"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 589",
      "S2 20 Cr. 330 (AJN)",
      "2086175.1",
      "DOJ-OGR-00008849"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge regarding a court case. The text is well-formatted and clear. There are no visible redactions or damage to the document."
}