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ay Case 1:20-cr-00330-PAE LB1TMAX1 Document 465 requiring alleged victims to publicl Filed 11/15/21 N Ww ws Oo OY ~] oO WO Ww a OY 20 21 22 23 24 25 their willingness to testify for chill fear of personal histories publicized. Raniere, Given the sensitive and inflammatory nature of conduct alleged, such publicity may cause embarrassment, forward. deterred from coming See, ma -D.N.Y. 2017), Docket No. 34. Limiting the disclosure of alleged victims' and other alleged victims of Martinez, Docket No. Page 8 of 127 8 y provide their names could F having their 622 at 32. the further harassment or sex crimes may be 17 CR 281, identities in this case true with the identities of alleged victims themselves, becaus identities would necessarily reveal the furthers these important interests. certain witnesses, the disclosure of The same is although not their identities of the alleged victims. First, the defens the contrary. not pose a threat to any of true, otherwise, but just because that reason disclosures possibility of other justifications. need here to prevent undue embarrassment, press and third parties, forward and report alleged abuse. sufficient notes that Ms. the witnesses. for limitin is absent in this case does not elimina And again, th and any resistance of That is harassmen SOUTHERN D STR (212) 805-0300 CT REPORTERS, P.C. others I'm not persuaded by defense counsel's arguments to Maxwell does plainly and the government does not argue or suggest or allege g te the ere is a t from the CO Come Cases establish that this is DOJ-OGR-00007059