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Case 1:20-cr-00330-PAE Document 717 Filed 07/12/22 Page3of10 The Honorable Alison J. Nathan December 12, 2021 Page 3 felt constrained not to help or not to be fully forthright in their testimony, which is exactly what will happen if these three witnesses are not given the same consideration as was given the government’s witnesses. Indeed, defense counsel have encountered significant resistance from former Epstein employees and acquaintances concerning their willingness or availability to testify because of fear related to unfavorable publicity should their names be publicly associated with Mr. Epstein. Numerous witnesses have refused to be interviewed, professed a lack of knowledge or memory, and actively avoided service of process because of the fear of public retaliation. ARGUMENT The Constitution grants Ms. Maxwell the right to present a defense and to compulsory process. U.S. Const. amends. V, VI. It also guarantees her effective assistance of counsel. U.S. Const amend. VI. To vindicate these rights, Ms. Maxwell requests that this Court permit three witnesses to testify using pseudonyms or their first names only. i —S—SSC es 22s known Ms. Maxwell and her family for almost forty years. She visited Ms. Maxwell in the United States at the various locations that are at issue in this trial during the relevant time periods. She met Jeffrey Epstein and can describe Ms. Maxwell’s interactions with Mr. Epstein.’ aa DOJ-OGR-00011322