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Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page6of8 the alleged harm to | | comes not through the mere fact of testifying as BS a Accordingly, the defendant’s argument has no connection to whether ii a are compromised; it is just an example of the generalized argument that testifying may pose reputational risk for | There is thus no basis in law to permit to testify under a pseudonym.4 Second, to the extent the defendant’s argument is rooted in more general concerns about harassment, intimidation, or risks to employment, those concerns arise in different forms for a large number of witnesses in this and any number of other cases. In this case, Government witnesses testified about their association with the defendant and Epstein in their true names, regardless of any feelings they may have had about their testimony. Those witnesses face the same generalized risks of harassment and negative implications of association with this case in the public eye as any defense witnesses. More broadly, this is hardly the first high-profile trial in this District, or this country, yet the defendant has identified no analogous circumstance in which the generalized concerns identified by the defendant justified the kind of anonymity order the defendant seeks. And in any number of other cases, witnesses are reluctant to testify publicly in 3 The defendant argues that J is similarly situated to the witnesses who testified as Matt and Shawn. (Def. Letter at 7). That comparison is unfounded. Matt and Shawn’s identities were protected for an entirely different reason: failure to do so would identify Jane and Carolyn, respectively. The defendant has not argued that identifying L would reveal the identity of some other protected witness. * Based on the limited information available to the Government so far, Ly profession appears to be irrelevant. Accordingly, insofar as the defendant could show some employment consequence for there would be no need for profession to be identified in open court. DOJ-OGR-00011238