DOJ-OGR-00005485.jpg

Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 30 of 69 The identity of the lawyers for the accusers may also be the subject of cross examination. The lawyers for the accusers have cooperated and shared information with each other and the government for yc. Is Substantial impeachment evidence exists as to [J under her real name, not a pseudonym. Ms. Maxwell should not be forced to compromise the full effect of this evidence by use of a first name only. The government’s proposal also creates substantial possibility for confusion. 3x OO —CSsSCSC‘CiésS OO —SCSCSCsis HE Given the age of the allegations and the potential for confusion by the witnesses the use of first names or fake names is untenable. Should the Court grant the government’s request it will also be confusing, and impossible to neutrally explain to the jury why some accusers are publicly identified by their real names while others are not. Any explanation will be prejudicial to Ms. Maxwell. reason for fake names. The request by the government is tactical. Having the court instruct the jury that, as a result of “privacy” or “safety” concerns, certain accusers or witnesses are being shielded affords the witness Court-sanctioned sympathy and credibility at Ms. Maxwell’s expense. To be clear, any accuser who testifies that Ms. Maxwell participated in sex abuse or sex trafficking is not telling the truth. Anonymizing false statements allows additional freedom to fabricate and impede potential witnesses from coming forward with countervailing testimony. DOJ-OGR-00005485