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fe NO Ww ws Oo OY ~] oO Ke) a oO a fe No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 Case 1:20-cr-00330-PAE LB1TMAX1 Document 465 Filed 11/15/21 pursuant to the Crime Victims Rights Act, Page 6 of 127 6 18 USC Section 3771, to permit certain witnesses and certain non-testifying witnesses to be re the issue of or specifically iden tifying in ferred to by pseudonyms. And there is also government requests pseudonyms or their The defense is already aware of of these individuals jury will also be aware of The request only implicates how those individual to in open court. This formation. first name. redacting related exhibits that contain the names the Specifically, that eight individuals be referred to by the identities of all , and as the government proposes it, the individuals' real identities. the is w Fol request for the The burden to justit starts with the government. limitation." at *l1, an Eastern 421 F.2d 1283 s are referred ll-tread territory, lowing reasons: Fy this It "mus United States v. Marcus, Marti, here would protect harassment other adverse consequences. (2d Cir. from the media and others, 1970). the alleged victims to protect the dignity and privacy of and I type of t provide a reason which is 2007 WL agree with the government that alleged victims. the will grant request, of course, for the 330388 District decision citing United States v. limiting disclosure from potential undue embarrassment and The Court has an obligation under the Crime Victims Rights Act to take certain measures at trial 18 USC SOUTH ERN D STR CT REPORT ERS (212) 805-0300 p PiGe DOJ-OGR-00007057