DOJ-OGR-00011326.jpg

Case 1:20-cr-00330-PAE Document 717 Filed 07/12/22 Page /7of10 The Honorable Alison J. Nathan December 12, 2021 Page 7 defense witness and “Maxwell apologist.” ggg has relevant and material information, and Ms. Maxwell has a constitutional right to present her testimony to the jury. This Court should safeguard Ms. Maxwell’s constitutional rights by affording gg the protection she seeks here. The countervailing considerations cannot outweigh gg request. First, there is nothing evidentiary or relevant about gg truc namc. ES Second, unlike Ms. Maxwell, the government does not have a constitutional right to confrontation. The government can fully cross-examine ggg without publicly disclosing her name. Publication of J true identity is unnecessary and unreasonable, just as this Court found it was with the alleged victims and Matt and Shawn. As the Court recognized in Alvarado v. Burge, “Testifying by giving an identifying number [or alias] rather than a [true] name does not necessarily curtail any trial rights. The cross-examiner can question the witness’ activities ... without regard to the witness’ name, and similarly has an opportunity to see and hear that which he testifies about.” No. 5 Civ. 1851(AKH), 2006 WL 1840020, at *2 (S.D.N.Y. June 30, 2006). This Court should permit ggg to testify using a pseudonym. B. Michelle Healy Michelle Healy has a substantial personal privacy interest in testifying using her first name only. During her testimony, Jane alleged that “Michelle” participated in sexualized massages and orgies with Mr. Epstein. From Jane’s description of “Michelle” in her testimony and her prior statements, it is clear that she is referring to Michelle Healy. Although Ms. Healy DOJ-OGR-00011326