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Case 1:20-cr-00330-PAE Document 438 Filed 11/12/21 Page9of54 the media” and “loss of employment potentially resulting from trial publicity.” Marcus, 2007 WL 330388, at *1. These interests significantly outweigh any defense interest, especially where the defense knows the true identities of victims and is able to mount their defense. See id.; Order at 2-3, Martinez, No. 17 Cr. 281 (ERK) (E.D.N.Y. Dec. 18, 2017), Dkt. No. 34.” Indeed, in two recent highly publicized cases in the Eastern District of New York, the district court judges permitted victims to testify using pseudonyms or using only their first names. In United States v. Raniere, No. 18 Cr. 204 (E.D.N.Y.), the Government moved to allow testifying victims to testify “under a nickname, first name, or pseudonym only, and to not be required to disclose uniquely identifying information,” such as “addresses, names of family members, or exact places of education or employment.” Order at 29, 32, Raniere, No. 18 Cr. 204 (E.D.N.Y. May 6, 2019), Dkt. No. 622. The Court granted the motion, explaining that “requiring victims of sex trafficking . . . and other crimes to provide their names in public could chill their willingness to testify,” and “would only cause further embarrassment and humiliation, given the inflammatory nature of the conduct alleged.” Jd. at 32, 35 (citations and internal quotation marks omitted). It also may “cause other victims to fear seeking help from law enforcement as that could subject them to further harassment and embarrassment.” /d. (citation and internal quotation marks omitted). Although the defendant claimed that several victims’ 2 Sex abuse cases are not unique. In other contexts, courts have permitted the Government to call witnesses using pseudonyms or using their first names only, notwithstanding a defendant’s Sixth Amendment rights. See, e.g., United States v. Schulte, 436 F. Supp. 3d 698, 706 (S.D.N.Y. 2020) (permitting use of pseudonyms in national security case); United States v. Hernandez, 12 Cr. 809 (PKC), 2013 WL 3936185, at *3 (S.D.N.Y. July 29, 2013) (permitting use of pseudonym for undercover agent in narcotics case). DOJ-OGR-00006369