Document 588

Case 1:20-cr-00330-PAE Document 588 Filed 01/28/22 Page 1 of 2 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 January 28, 2022 By ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in response to the Court's Order dated January 26, 2022 regarding the redaction of a witness's name in one court exhibit. (Dkt. No. 584). The Government does not seek to redact the last name of the witness who testified as Carolyn in Court Exhibit 2, because Carolyn publicly disclosed her full name in a post-trial interview with the Daily Mail, in which she identified herself as the witness who had testified under the name Carolyn at trial, and stated that she waived her right to anonymity. The Government notified Carolyn through her counsel that it intended to take this position and Carolyn's counsel has confirmed that Carolyn does not object to her last name being used in filings going forward. 1 DOJ-OGR-00008847 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 588 Filed 01/28/22 Page 2 of 2 Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (by ECF) 2 DOJ-OGR-00008848