{
  "document_metadata": {
    "page_number": "2",
    "document_number": "589",
    "date": "01/28/22",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 589 Filed 01/28/22 Page 2 of 3\nThe Honorable Alison J. Nathan\nJanuary 25, 2022\nPage 2\nI waive my right to anonymity. I am doing this because I want all young women to know what happened to me when I was a teenager and how it has affected my life. I want to be a voice for all survivors of sexual abuse so that they are not afraid to come forward, even if it is years after the event, and say what happened to them. This is my story and I want to tell it.1\nThe defense told the government that, in light of Ms. Andriano's statements, we did not see any privacy interest that could justify redacting her name in any further court filings.\nAlthough we did not receive a response from the government, the government ultimately sent the Court a proposed redacted version of Court Exhibit 2 which redacted the full names of witnesses who testified under pseudonyms and the last names of witnesses who testified using only their first names. The government also followed the defense's request and did not redact Ms. Andriano's last name.\nCarolyn Andriano is now in the same position as Annie Farmer, who publicly waived her right to anonymity and gave public statements to the media under her full name. Accordingly, the defense respectfully submits that Ms. Andriano's last name should not be redacted in the version of Court Exhibit 2 that is filed on the public docket.\nThe defense files this letter temporarily under seal until the Court rules on whether Ms. Andriano's last name should be redacted. Once the Court rules, we will file an appropriately redacted version of this letter on the public docket and coordinate with the government to provide the Court with an updated version of Court Exhibit 2, if necessary.\n1 See https://www.dailymail.co.uk/news/article-10380313/Victim-waives-claims-Virginia-Giuffre-told-slept-Duke-York-London.html (emphasis added).\n2086175.1 DOJ-OGR-00008850",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 589 Filed 01/28/22 Page 2 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nJanuary 25, 2022\nPage 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "I waive my right to anonymity. I am doing this because I want all young women to know what happened to me when I was a teenager and how it has affected my life. I want to be a voice for all survivors of sexual abuse so that they are not afraid to come forward, even if it is years after the event, and say what happened to them. This is my story and I want to tell it.1",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The defense told the government that, in light of Ms. Andriano's statements, we did not see any privacy interest that could justify redacting her name in any further court filings.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Although we did not receive a response from the government, the government ultimately sent the Court a proposed redacted version of Court Exhibit 2 which redacted the full names of witnesses who testified under pseudonyms and the last names of witnesses who testified using only their first names. The government also followed the defense's request and did not redact Ms. Andriano's last name.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Carolyn Andriano is now in the same position as Annie Farmer, who publicly waived her right to anonymity and gave public statements to the media under her full name. Accordingly, the defense respectfully submits that Ms. Andriano's last name should not be redacted in the version of Court Exhibit 2 that is filed on the public docket.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The defense files this letter temporarily under seal until the Court rules on whether Ms. Andriano's last name should be redacted. Once the Court rules, we will file an appropriately redacted version of this letter on the public docket and coordinate with the government to provide the Court with an updated version of Court Exhibit 2, if necessary.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "1 See https://www.dailymail.co.uk/news/article-10380313/Victim-waives-claims-Virginia-Giuffre-told-slept-Duke-York-London.html (emphasis added).",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "2086175.1 DOJ-OGR-00008850",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Carolyn Andriano",
      "Annie Farmer",
      "Virginia Giuffre"
    ],
    "organizations": [
      "Daily Mail"
    ],
    "locations": [
      "London",
      "York"
    ],
    "dates": [
      "January 25, 2022",
      "01/28/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 589",
      "2086175.1",
      "DOJ-OGR-00008850"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. It discusses the waiver of anonymity by a victim and the redaction of names in court documents. The document is well-formatted and legible."
}