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Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page4of8 that “[t]here is no allegation that 1 is a victim of any improper or illegal conduct by Mr. Epstein or Ms. Maxwell” and offers no suggestion that i would face any particularized harm should she testify under her true name. (Def. Letter at 8). She is no different from the several Government witnesses who were closely associated with Maxwell and Epstein who have already testified under their true names. There is accordingly no legal basis for to testify under a pseudonym. For Michelle Healy, the defendant claims that she is the same Michelle who, on cross- examination, Jane recalled participating in sexualized massages with her and Epstein after Jane reached the age of consent and moved to New York.” On this theory, which the Government disputes, the defendant claims Healy is a victim-witness entitled to the same solicitude as the victims who testified in the Government’s case-in-chief. (Def. Letter at 7-8). The defendant’s position is misplaced. First, the defendant has not established that Healy is the same Michelle that Jane referenced in her testimony. Indeed, the Government anticipates filing a separate motion to preclude Healy’s testimony in part because there is an insufficient basis to find that Healy’s testimony would in fact contradict Jane’s. Second, and relatedly, it appears based on the defendant’s Rule 26.2 disclosures that Healy will testify that she was not a victim of Epstein and the defendant. (Presumably, if she were, the defendant would not be calling Healy.) Unlike the Government’s victim-witnesses, then, Healy’s testimony will contain no explicit details about sexual abuse, her dignity and privacy are not at * The Government disputes this characterization of Jane’s testimony: Jane testified on cross- examination that a “Michelle” participated in those massages, not that Michelle Healy did so. Defense counsel chose not to ask for a last name or otherwise attempt to identify to which “Michelle” she was referring. 4 DOJ-OGR-00011236