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Case 1:20-cr-00330-AJN Document 34 Filed 07/28/20 Page 2 of 2 who has spoken—or who at some future time speaks—by name on the public record in this case, and otherwise be permitted to identify victim names in sealed filings, or identify victims by pseudonyms in public filings, or redact victim names in public filings, but that the defendant and her counsel be restricted from otherwise publicly referencing witness or victim identities. That disagreement is reflected in the differences between the Government’s proposed order paragraphs 5, 6, 8, and 16 and the corresponding defense proposed paragraphs 6, 7, 9, and 17. b. Second, the defendant and her counsel have proposed certain restrictions on the Government and potential Government witnesses and their counsel. For the reasons set forth in the Government’s accompanying letter, the Government does not believe that such restrictions are warranted or appropriate. That disagreement is reflected in the defendant’s proposed paragraph 3, which does not have a corresponding paragraph in the Government’s proposed order, and in the differences between the Government’s proposed order paragraph 4 and the corresponding defense proposed paragraph 5. 4. I hereby certify that the foregoing statements made by me are true. Dated: New York, New York July 28, 2020 Alex Rossmiller Assistant United States Attorney Telephone: (212) 637-2415 DOJ-OGR-00001684