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Case 1:20-cr-00330-PAE Document 717 Filed 07/12/22 Page6of10 The Honorable Alison J. Nathan December 12, 2021 Page 6 adverse consequences.” TR 11/1/2021, p 6:20-23. The harassment and intimidation yg will experience if it becomes public that she testified at the request of Ms. Maxwell cannot be overstated. If her identity is revealed, My will be a prime target for media hysteria and harassment in all its forms. At trial, this rationale for anonymity extended beyond the alleged victims themselves to include several witnesses and third parties. Exhibits with witness or third-party identifying information were filed under seal or redacted. (As noted above, there were at least forty-five times when an exhibit or series of exhibit was admitted either partially or fully under seal to protect the identity or privacy of a victim, third party, or witness.) Thus, even though yg is not an alleged victim in this case, that does not mean she lacks profound professional and personal privacy interests in not having her true name revealed in public. Likewise, ay should be afforded the same privacy protection as have other witnesses whose true or full identity has been safeguarded—courtroom artists should be precluded from drawing her true facial likeness. Finally, Ms. Maxwell’s constitutional rights to present a defense, to compulsory process, and to effective assistance counsel would be compromised without the protection of anonymity requested here. U.S. Const. amends. V, VI. As this Court said at the pretrial conference, “[g]iven the sensitive and inflammatory nature of the conduct alleged, such publicity may cause further harassment or embarrassment, and other alleged victims of sex crimes may be deterred from coming forward.” TR 11/1/2021, p 8:4-7. This logic applies with equal force to witnesses called by the defense. As to J in particular, there is no question she will face vitriol, harassment, and intimidation once she yy is publicly labeled asa DOJ-OGR-00011325