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Case 1:20-cr-00330-AJN Document 511 Filed 11/27/21 Page 2 of 3 particular page. We have considered these concerns and would like to propose a solution that we believe will address these issues and safeguard the privacy interests of the witnesses, and at the same time provide for an efficient trial and protect Ms. Maxwell’s rights. The defense proposes that the parties be permitted to display documents used for impeachment or refreshing recollection only on the video screens used by the witness, the Court, and the Court’s deputy. None of these screens face the gallery or the jury box and cannot be seen by anyone in the audience or by members of the jury. The documents will not be displayed on the screens at counsel table, which face the gallery, or on the juror screens. While the defense may display a particular page of a document to the witness to impeach or refresh recollection, we will have the complete document available in electronic form. If the witness wishes to see other pages of the document, we can display those pages on the witness’s screen at the witness’s request. Most importantly, this process will allow counsel to highlight or direct the witness’s attention electronically to particular sections of the 3500 materials, without having to describe the particular paragraph number or sentence in (sometimes) voluminous, dense, multi-page FBI 302 reports. Additionally, it will ensure that the witness is looking at the correct exhibit, rather than at other potential impeachment material in a binder before them, especially since defense counsel is not placed in a position within the courtroom that permits us to see what exhibit or page the witness has open in front of them on the witness stand. Finally, it will obviate the need to approach a witness, which is difficult with the Covid protocols and courtroom set-up, to direct the witness to a particular exhibit or section of an exhibit. The government has advised that it does not require copies of any of the 3500 materials or the government exhibits. If the defense uses any documents to impeach or refresh recollection that are not DOJ-OGR-00008167