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Case 1:20-cr-00330-PAE Document 717 Filed 07/12/22 Page9of10 The Honorable Alison J. Nathan December 12, 2021 Page 9 and because nondisclosure of her true name will not deprive the government of the ability to meaningfully cross-examine her, Ms. Healy’s interest in remaining anonymous outweighs any government interest, “especially where the [government] knows the true identit[y] of [Ms. Healy].” Gov. Mot. in Limine, p 8 (citing cases). CONCLUSION When this Court read its preliminary instructions to the jury, it said: As I mentioned during jury selection, this case has received and will continue to receive significant attention in the media. To protect their privacy, I have permitted witnesses, if they choose, to be referred to in open court by either their first name or a pseudonym. The full names of the witnesses are known to the government, the defendant, to the Court, and were shown to you during jury selection. This process should not bear in any way on your evaluation of the evidence in this case. TR 11/29/2021, pp 24-25. Several government witnesses testified using pseudonyms or only their first names. The logic of allowing that process applies with equal if not greater force here, given Ms. Maxwell’s constitutional rights to present a defense, to compulsory process, and to effective assistance of counsel. These three defense witnesses merely ask for the same consideration given the government’s several witnesses. Because their professional and personal privacy concerns are significant and substantial, and because testifying under a pseudonym or a first name will not affect the government’s ability to fairly cross-examine them, this Court should permit yyy. Ms. Healy, and Ms. J to testify using pseudonyms or their first names only, just as it permitted Jane, Kate, Carolyn, Matt, and Shawn to do, and the courtroom artists should be precluded from sketching their faces. DOJ-OGR-00011328