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Case 1:20-cr-00330-PAE Document 717 Filed 07/12/22 Page4of10 The Honorable Alison J. Nathan December 12, 2021 Page 4 Re: is. Maxwell expects her to testify on Monday, December 20. This Court should permit gg to testify using a pseudonym. First, I bas a substantial professional interest in testifying using a pseudonym. Put simp], [a HEE is justifiably worried that she will be denounced and ostracized by her colleagues should it become a mater of public record that she testified at the request of Ms. Maxwell’s defense team. See, e.g., United States v. Marti, 421 F.2d 1263, 1266 (2d Cir. 1970) (proper for court to preclude defense from revealing witness’s address when that information “may subject the witness to reprisals”). Her testimony in this case, if revealed, presents a real threat to her employment. See United States v. Marcus, No. 05 CR 457 (ARR), 2007 WL 330388, at *1 (E.D.N.Y. Jan. 31, 2007) (pseudonymity may be appropriate “to avert loss of employment potentially resulting from trial publicity”). ee ee ee es. (7 TR 11/1/2021, p 8:1-3 DOJ-OGR-00011323