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Page 2 The Government submits that this nomenclature can be used when trial begins on November 29, 2021, but that the parties should be directed to continue referencing victims and witnesses on the public record according to the nomenclature in the Superseding Indictment. The Government further requests that the defense be directed to redact the true names of the witnesses in this chart from all exhibits to filings, and to avoid using the true names of victims in filings with the Court. Using the true names of victims delays public filings and creates otherwise unnecessary redaction projects that waste the Government and the Court’s time. Moreover, using victim names in filings increases the risk that victim identities may become public, due to redaction errors or other issues. I. Voir Dire Regarding voir dire, the Government proposes that prospective jurors be handed a sheet with a list of names and places that may come up at trial. That sheet, which would be filed under seal, would contain the true names of witnesses. The sheet would not be read aloud; instead, the DOJ-OGR-00006354