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Case 1:20-cr-00330-PAE Document 438 Filed 11/12/21 Page14 of 54 stigma. These details are “inflammatory” in light of the “nature of the conduct alleged.” Order at 32, United States v. Raniere (May 6, 2019), Dkt. No. 622. Minor Victims-1 through -4 are expected to testify in explicit detail and/or be the subject of highly sensitive and personal testimony concerning illegal sexual abuse by the defendant and Epstein, much of which occurred while they were under the age of 18. While Minor Victim-5 and Minor Victim-6 will not testify, similar details are expected to be elicited as to them. These details will likely appear in the news and on the internet, but the Court can ensure that they will not be publicized side-by-side with the victim’s true name. See Order at 2-3, Martinez, No. 17 Cr. 281 (ERK) (E.D.N.Y. Dec. 18, 2017), Dkt. No. 34 (“This case has already received significant national and local press coverage. Revealing Jane Doe’s identity would likely cause her anxiety and risk social stigma.”). Second, the publicity increases the personal and professional consequences to the Minor Victims for testifying. One Minor Victim has expressed substantial concern to the Government about the risks that her association with this case will pose to future employment. Making that association widely public—for that victim and others—requires the Minor Victims to be associated with the graphic details of their experiences, not just in the general public consciousness, but with their friends, families, colleagues, and prospective employers. Third, the publicity increases the risk that the Minor Victims will be harassed by the press and public. In light of the significant media attention this case has generated, it is likely that the Minor Victims will be approached and harassed by members of the press and the public after 13 DOJ-OGR-00006374

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Filename DOJ-OGR-00006374.jpg
File Size 643.8 KB
OCR Confidence 94.1%
Has Readable Text Yes
Text Length 1,865 characters
Indexed 2026-02-03 17:10:28.728755