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Case 1:20-cr-00330-PAE Document 438 Filed 11/12/21 Page13 of 54 examination of other witnesses; (2) preclude the defense from eliciting personal identifying information for the Minor Victims, Witness-1, Witness-2, Witness-3, or Witness-4, including their addresses or the details of their current employment; and (3) seal exhibits containing the names of Minor Victim-1, Minor Victim-3, and Witness-1, or the last names of Minor Victim-4 and Minor Victim-6. To be clear, the Government’s request is that those names not be stated in open court or read into the record. The defendant already knows the true names of these victims and witnesses. And the Government expects the jury to learn the true names of the relevant minor victims and witnesses at trial. The Government intends to offer documentary evidence that would corroborate the testimony of the Minor Victims and which contains the names of certain of the Minor Victims. While those names may remain hidden from the public, they will be revealed to the jury.? Since the defendant’s arrest, this case has garnered significant media attention, and the Government expects that members of the media will attend and report on the trial. Under these circumstances, it is highly likely that, if stated publicly in open court, the names of the Minor Vietims willbe widely pueda That publicity imposes real costs on the Minor Victims and the public. First, publicizing the names of the Minor Victims will cause them significant embarrassment, anxiety, and social 3 This can be accomplished simply. For instance, the jury can learn Minor Victim-1’s name by displaying a document containing Minor Victim-1’s name for the witness and the jury—but not the public—and asking Minor Victim-1 whether the name on the document is her name. 12 DOJ-OGR-00006373