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Case 1:20-cr-00330-PAE Document 717 Filed 07/12/22 Page1of10 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca oO 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jeagliuca@hmflaw.com HADDON MORGAN FOREMAN December 12, 2021 VIA Email The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: — United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, As directed, I write to request that the Court permit three witnesses called by the defense to testify using pseudonyms or their first names only. Those witnesses are J, Michelle Healy, and a. Ms. Maxwell submits this letter at the request of these witnesses.! Ms. Maxwell has conferred with the government about this request. The government opposes any form of protective anonymity for these witnesses. BACKGROUND So far, there have been ten trial days in this case. During that time, several witnesses have testified using a pseudonym or their first name only. These witnesses include three of the four alleged victims (Jane, Kate, and Carolyn) and two other government witnesses (Matt and ' Ms. Maxwell may call as witnesses individuals who share the same true last name as the alleged victims in this case. Consistent with this Court’s earlier ruling, and subject to her earlier objections, Ms. Maxwell does not oppose these witnesses testifying using pseudonyms or their first names only. DOJ-OGR-00011320