DOJ-OGR-00011235.jpg

Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page3of8 witnesses using pseudonyms or first names, and to redact or seal certain exhibits, as a further measure to protect the identities of the four Minor Victims. The Government did not argue that those witnesses merited pseudonyms on their own, but rather that they needed derivative anonymity to protect the Minor Victims. Numerous other witnesses testified at trial for the Government under their true name, including those closely associated with the defendant and Epstein, such as Larry Visoski, Juan Alessi, David Rodgers, and Nicole Hesse. And the Government did not seek anonymity for a number of other witnesses the Government ultimately did not call at trial.+ The defendant now seeks anonymity protection for three lay witnesses, none of whom are offered to testify as victims of sexual abuse: a. Michelle Healy, and i. II. Discussion The defendant’s motion should be denied for two reasons. First, it seeks anonymity for categories of witnesses that courts generally have not previously permitted to testify with their identities protected. Second, the defendant’s request does not implicate her right to a fair trial or to present a defense. First, none of the defense witnesses satisfy any of the established categories of witnesses who courts have permitted to testify under pseudonyms. The defendant does not even suggest that P fits into any such category. (Def. Letter at 8-9). Indeed, the defense concedes ' The Government also offered a large number of exhibits under seal or in redacted form. Those requests largely, if not entirely, concerned (1) witnesses whom the Court permitted to testify using pseudonyms or under their first names; (2) personal identifying information, such as addresses; (3) information related to third parties, that is, individuals who are not testifying at trial or at issue in the case; or (4) exhibits where information for testifying witnesses was co-mingled with private information so extensively that redactions were impractical. 3 DOJ-OGR-00011235