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Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page1of8 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 December 14, 2021 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, 82 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in opposition to the defendant’s request to permit three witnesses to testify using pseudonyms or first names. The defendant’s unprecedented request seeks relief for an issue that arises in a large number of cases, and that relief is not necessary to protect the defendant’s constitutional rights. Accordingly, the Government opposes the motion. 1. Applicable Law It is “firmly established” that “the press and general public have a constitutional right of access to criminal trials.’ Globe Newspaper Co. v. Superior Court for Norfolk County, 457 U.S. 596, 603 (1982); see United States v. Alcantara, 396 F. 3d 189, 194-95 (2d Cir. 2005) (describing the “qualified First Amendment right to attend trials”). It is well settled that the names of certain categories of trial witnesses can be withheld from DOJ-OGR-00011233