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Case 1:20-cr-00330-PAE Document 383 _ Filed 10/29/21 Page 15 of 40 C. The Government’s Proposal Would Protect Those Privacy Interests The Government has proposed permitting Minor Victim-1, Minor Victim-3, and two witnesses related to Minor Victim-1 to testify under pseudonyms, and limiting reference to them at trial to those pseudonyms. The Government has also proposed permitting Minor Victim-4 and certain witnesses related to her to testify under their first names, and limiting reference to those witnesses and Minor Victim-6 to their first names. This proposal would successfully protect the victim privacy interests identified above. The question is not whether the victims’ testimony—that is, the intimate details of their childhood sexual abuse at the hands of the defendant and Jeffrey Epstein—will become public. They will, and in light of the publicity surrounding this case, those details are likely to be highly publicized. The question is whether those details will be linked to the names of the Minor Victims. Under the 8 Although the defense also says it needs to investigate Minor Victim-6 as a “potential witness” (Def. Opp. at 20), as the Government has said before, Minor Victim-6 will not be a witness or hearsay declarant at this trial. 14 DOJ-OGR-00005569