Case 1:20-cv-00484-JGK-DCF Document 118 Filed 11/29/21 Page 1 of 2 Case 1:20-cv-00484-JGK-DCF Document 117 Filed 11/24/21 Page 1 of 2 PANISH SHEA & BOYLEI November 24, 2021 4 Cue-PG--E/CE VIA ECF Hon. John O. Koeltl Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 0 1d ref./247f Oecea-4L4 .9-0,-.11 'ft °Pe", pin-ie/: (gig) 767 -Lt. 'Pt". 4ccerf corn: Itt0011. S' Re: Doe v. Indyke, et al., 1:20-cv-000484-JGE-DCF Dear Judge Koeltl: Gvg‘t, 9f if FLO tm-o6,40 c/(5 1e-e - O-9/,,JVc PlaintiffJane Doe hereby responds to the letter submitted by Ms. Maxwell's defense counsel on November 22, 2021 seeking authorization from this Court to disclose an unredacted copy of the settlement release as part of Ms. Maxwell's criminal defense. As this Court previously stated in its Memorandum Opinion and Order (ECF No. 32), "the plaintiff has an understandable interest in maintaining her anonymity, and the Court entered an order to protect it." Asa condition of the dismissal of this action, Plaintiff produced to Ms. Maxwell an authentic, unredacted and signed copy of the settlement release. Plaintiffs anonymity, however, would be severely compromised if an unredacted copy of the release were to be used by Ms. Maxwell "as part of her criminal defense." Indeed, nowhere in Ms. Maxwell's letter does she actually state how the unredacted release would be used in her criminal case or which witnesses or persons she would show it to. Accordingly, and contrary to this Court's previous ruling, there is no way of knowing that the unredacted copy of the release will be "used only for a proper purpose." (Id. at 6). Plaintiff is also unaware of what protections are in place, if any, in the criminal case that would maintain her anonymity in the event that an unredacted copy of the release was to be used in some way by Ms. Maxwell. Further, it is Plaintiff's understanding that Ms. Maxwell's Rule 17(c) subpoena issued to the EVCP for the settlement release has