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Case 1:20-cr-00330-PAE Document 380 Filed 10/29/21 Page11of54 B. Discussion The victims are expected to testify in explicit detail and/or be the subject of highly sensitive and personal testimony concerning sexual abuse, most of which occurred while they were under the age of 18. The limited protections requested by the Government are reasonable, necessary, and narrowly tailored to protect the victims’ well-being, prevent undue embarrassment and other adverse consequences, including loss of employment, and prevent the victims from being harassed by the press and others. Specifically, the Government requests that Minor Victim-1 and Minor Victim-3- —be permitted to testify under a pseudonym. || Additionally, — on) DOJ-OGR-00005404