DOJ-OGR-00005397.jpg

Case 1:20-cr-00330-PAE Document 380 Filed 10/29/21 Page4of54 Po Eleventh, and finally, the Government moves to preclude the defense from misleadingly suggesting to the jury that the defendant prevailed in civil litigation related to the facts of this case. For the reasons set forth below, the Court should grant the Government’s motions. ARGUMENT 1. The Court Should Permit Certain Witnesses to Testify Under Pseudonyms or Using First Names, and Permit the Sealing of Related Exhibits The Government requests, pursuant to the Crime Victims’ Rights Act, that the Court take certain measures at trial to protect the dignity and privacy of victims. See 18 U.S.C. § 3771(a)(8). The Government expects the four Minor Victims named in the Indictment to testify at trial. In the course of their testimony—and the corroborating testimony of other trial witnesses—the jury will learn that two other minors (Minor Victim-5 and Minor Victim-6) were also victims of the conspiracies charged in the Indictment. Specifically, Minor Victim-4 will testify that she was recruited by Minor Victim-5, and that she in turn recruited Minor Victim-6. Neither Minor Victim-5 nor Minor Victim-6 will testify at trial. In order to protect the privacy of crime victims, the Government respectfully requests that the Court take certain measures at trial, which are narrowly tailored to the particular circumstances and privacy interests of each victim and consistent with the protections victims of sex crimes have been afforded in recent federal trials. To be clear, the defense is already aware of the identities of all of these victims and witnesses, and the jury will be made aware of the identities of these victims and witnesses. The Government simply proposes measures that will DOJ-OGR-00005397