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Céasb: 2@20rOCRRSPAGN Demument4e2 Abbey Paétpege aft 7 . U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building EPSGATS —_ ' One Saint Andrew’s Plaza USDC SDNY New York, New York 10007 DOCUMENT ELECTRONICALLY FILED et ae ne ree November 10, 2021 DATE FILED: 11/11/21 BY EMAIL ) The parties are ORDERED to submit the lists The Honorable Alison J. Nathan referenced in this letter on or before November 14, United States District Court 2021, in accordance with Dkt. No. 427. The parties Southern District of New York may continue submitting proposed redactions in United States Courthouse accordance with the procedures this Court has 40 Foley Square previously set. SO ORDERED. New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Ale \) iff 41/11/21 Dear Judge Nathan: At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint letter regarding protections for witness identities at trial. In particular, the Court directed the parties to: (1) provide nomenclature for witnesses whose identities should be protected, (2) propose procedures for voir dire related to witness identities, (3) submit a proposed instruction to the jury regarding witnesses testifying under pseudonyms or under their first name only, and (4) address the logistics of offering sealed or redacted exhibits containing personal identifying information. Below are the positions of the parties regarding these logistical considerations. Because this letter contains identifying information relating to victims, the Government respectfully requests that the Court accept the Government’s proposed redactions to this letter. Government position: 1. Nomenclature With respect to nomenclature for witnesses whose identities should be protected at trial, the Government respectfully submits the following chart, which provides the true names of witnesses and the proposed nomenclature for those witnesses at trial. DOJ-OGR-00006353