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Case 1:20-cr-00330-PAE Document 432 Filed 11/10/21 Page5of5 Page 5 Defense position: In light of the Court’s ruling on the government’s motion in limine, the defense will accept the government’s proposed nomenclature for the witnesses referenced above. The defense has no objection to the procedures proposed by the government for voir dire and for sealing and redacting exhibits on the understanding that the defense will have the opportunity to object to particular sealing and redaction requests. The defense also proposes the following limiting instruction in place of the government’s proposed instruction: This case has received, and will continue to receive, significant attention in the media. To minimize the inconvenience and potential harassment of any witness, the Court has permitted witnesses, if they choose, to be referred to by either their first name or a pseudonym. However, the full names of the witnesses are known to the Government, the defendant, and to the Court, and were shown to you during jury selection. This process should not bear in any way on your evaluation of the evidence in this case. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: __s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (By email) DOJ-OGR- 00006337