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Case 1:20-cr-00330-PAE Document 432 Filed 11/10/21 Page3of5 Page 3 Government requests that the Court direct prospective jurors to read the sheet and to raise a hand if they are familiar with the witnesses or locations. Examination of jurors on this subject would then be conducted at sidebar, with the transcript redacted to remove witness identifying information. il. Limiting Instruction The Government requests that the Court give the jury an instruction that is similar to the instruction Judge Garaufis gave the jury in United States v. Raniere, 18 Cr. 204 (E.D.N.Y.). In that case, Judge Garaufis instructed the jury: You may have noticed during yesterday's testimony that the witness used first names of certain individuals. That is because the names of certain alleged victims are being withheld from the public and the press to protect the privacy of those individuals. I have therefore instructed the parties to refer to those individuals by their first names only; however, those full names are known to the Government, the defendant, and to the Court. An excerpt of the relevant transcript is enclosed as Exhibit A. Here, the Government proposes that the Court instruct the jury: At this trial, certain witnesses will be testifying under their first name only. Other witnesses will be testifying under pseudonyms — that is, under different names. That is because the names of certain alleged victims and related witnesses are being withheld from the public and the press to protect the privacy of those individuals. I have therefore instructed the parties to refer to those individuals by their first names only, or in some instances, by using a pseudonym. However, the full names of the witnesses are known to the Government, the defendant, and to the Court. The Government respectfully submits that the proposed instruction addresses any potential DOJ-OGR-00006335