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Case 1:20-cr-00330-PAE Document519_ Filed 11/30/21 Page2of3 The Honorable Alison J. Nathan November 30, 2021 Page 2 Not only that, but the government’s direct examination of Jane today would have violated its own proposal—for example, the government elicited testimony about where Jane attended school and during what years, a prime example of a “specific location” and “particular dates of life events” the government now seeks to prevent Ms. Maxwell from eliciting on cross- examination. The government’s proposal is also contrary to this Court’s earlier ruling permitting Ms. Maxwell to confront her accusers by eliciting evidence of their story lines. We will remain cognizant of our duty to avoid revealing the names of witnesses testifying under pseudonyms. And we will alert the government and the court in advance as we are able to anticipate any issues. DOJ-OGR-00008203