DOJ-OGR-00001921.jpg

be N Ww ws Oo OY ~] oO Ke) a fan) = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 44 of 91 44 k7e2MaxC kjc confidentiality, see in a moment, that explains is putting on Your Honor, as your Honor pointed out. hav And as you will a lot of the spin the government facts in this case. peopl client has received them. received them. Most of received death threats. received physical threats. My those close to her have They hav been injured in their jobs, their reputations, simply The It's out there. through just to make proceeding is also a reality. is a real There thing significant impact on our client. normally come From the Pretrial 1s aware of for knowing my client. facts of all the steps the court the public access available to forward as part of They have in their work opportunities, in It's real. had to go this out there having a very There are folks who would a bail package who your Honor Services report who can't now, at least at this point, concerns. Since last week our Haddon Morgan have b This because of n besieged with e-mails and posts, is all the safety and confidentiality firm alone and my colleagues at some of them threatening. attempts to poo-poo it, to give very real, and we submit it is a factor very real. The government it the back of the hand. It is For the court to consider in its discretion. Before I go further, through the 3142(g) analysis. like to make one comment about your Honor, But before [ would like to go I would [ do that, the CVR -- CVRA proceeding under SOUTHERN D STRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001921