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Extracted Text (OCR)
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
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DOJ-OGR-00006374
Extracted Information
Document Details
| 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 |