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Case 1:20-cr-00330-PAE Document 440 Filed 11/12/21 Page5of40 ee. That misses the point entirely. The Court must decide whether to protect the privacy of four victims who will testify in a criminal trial, for the first time in their lives, about the painful details of the sexual abuse they were subjected to as children. The answer to that question is emphatically yes. The defense has failed to articulate any particularized need to publicize the full names of the Minor Victims. Nor could they, since the full names are known to the defense and the Court, and will be known to the jurors in this case. And the Government’s narrowly tailored proposal balances the public interest in access to information with the Minor Victims’ right to privacy and dignity. The Court should grant the motion. A. Applicable Law As the Government explained in its motions (Gov’t Mot. at 4-9), if the Government provides a reason to “limit disclosure of identifying information in open court,” the defendant must “demonstrate a ‘particularized need’ for disclosure . .. which the court weighs against the risks to the witness.” United States v. Marcus, No. 05 Cr. 457 (ARR), 2007 WL 330388, at *1 (E.D.N.Y. Jan. 31, 2007) (citing United States v. Marti, 421 F.2d 1263, 1266 (2d Cir. 1970); United States v. Bennett, 409 F.2d 888, 901 (2d Cir. 1969)), aff'd, 628 F.3d 36, 45 n.12 (2d Cir. 2010)); see United States v. Urena, 8 F. Supp. 3d 568, 572-73 (S.D.N.Y. 2014) (permitting an undercover law enforcement officer to testify under a pseudonym, after balancing the relevant interests); cf’ United States v. Cavallaro, 553 F.2d 300, 304 (2d Cir. 1977) (“[W]here the government voices a legitimate concern for a witness’ safety, the trial court must balance the potential danger to the witness against the need of the defense for the information.”). DOJ-OGR-00006521