MANLEYS

MANLEYS SOLICITORS Strictly Private and Confidential Hon. Alison J. Nathan Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 By Email ONLY Date 21.t April 2021 Our Ref MJM/TAYO/1 Your Ref: Dear Judge Nathan, STRICTLY PRIVATE AND CONFIDENTIAL We represent a former PA to Ghislaine Maxwell. We are writing to you ahead of Maxwell's upcoming criminal trial to request that all variations of our client's name be redacted from court papers. We have copied both the Prosecutor and Defence lawyer into this email. We are mindful of the Order of District Judge Alison J. Nathan dated April 19th 2021 requiring any requests for redaction of documents by today - April 210 2021. This letter/email is such a request. In the previous defamation proceedings between and Ghislaine Maxwell, our client was not initially made aware by the court or any of the representatives of the parties of the availability to make an application for her name to be redacted