DOJ-OGR-00005401.jpg

Case 1:20-cr-00330-PAE Document 380 Filed 10/29/21 Page8of54 Zhong, No. 16 Cr. 614 (DLI), 2018 WL 6173430, at *2 (E.D.N.Y. Nov. 26, 2018) (granting government’s motion to have victim witnesses testify using pseudonyms); Order at 2-3, United States v. Martinez, No. 17 Cr. 281 (ERK) (E.D.N.Y. Dec. 18, 2017), Dkt. No. 34 (“Jane Doe will be permitted to testify as ‘Jane Doe’ at trial, and will not be required to disclose her address, names of family members or exact place of employment (if any).”); Apr. 5, 2016 Tr. at 6-10, United States v. Quraishi, No. 15 Cr. 598 (CBA) (E.D.N.Y.), Dkt. No. 46 (permitting a witness to testify using only her first name); United States v. Corley, No. 13 Cr. 48 (AJN), 2016 WL 9022508, at *3-4 (S.D.N.Y. Jan. 15, 2016) (noting that “Judge Patterson . . . permitted the minor victims to testify under a pseudonym at trial” and denying the pro se defendant’s request for the surnames of the minor victims for his appeal); United States v. Graham, No. 14 Cr. 500 (ER), 2015 WL 6161292, at *10 (S.D.N.Y. Oct. 20, 2015) (permitting victims to testify using their first names only); Order at 2, United States v. Rivera, No. 09 Cr. 619 (JIMA) (E.D.N.Y. Apr. 26, 2011), Dkt. No. 231; United States v. Paris, No. 06 Cr. 64 (CFD), 2007 WL 1484974, at *2 (D. Conn. May 18, 2007). Because of the explicit nature of the offense conduct, which may require victims to testify about “degrading and humiliating treatment,” revealing victim identities “would likely cause . . . anxiety and risk social stigma,” and “could chill the willingness of other alleged victims of sex crimes to come forward.” Order at 2, Martinez, No. 17 Cr. 281 (ERK) (E.D.N.Y. Dec. 18, 2017), Dkt. No. 34. Additionally, victims in sex abuse cases suffer from “likely adverse personal, professional and psychological consequences of publicly linking their identities to their past” conduct. Paris, 2007 WL 1484974, at *2. “In light of the explicit nature of the conduct” that is the subject of the case, victims have “legitimate” fears “of harassment by DOJ-OGR-00005401