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Case 1:20-cr-00330-PAE Document548- Filed 12/15/21 Page2of6 At a conference on November 1, 2021, the Court granted the Government’s motion in limine to permit alleged victims to testify under pseudonyms and, as a consequence, to redact their real identities from exhibits. Nov. 1 Tr. at 6. That motion was granted for two primary reasons. First, the Court has a statutory duty to protect an alleged crime victim’s “right to be treated with fairness and with respect for the victim’s dignity and privacy.” 18 U.S.C. § 3771(a)(8). Nov. 1 Tr. at 6-7. Because of the “sensitive and inflammatory nature of the conduct alleged” the Court found that pseudonyms were necessary to protect that right. /d. at 8. Second, if alleged victims of abuse were subject to publicity, harassment, and embarrassment, “other alleged victims of sex crimes may be deterred from coming forward” to report abuse. /d. The Court emphasized that the Government’s proposal is “quite common” among courts in this circuit, citing six such cases. /d. at 7-8. As a consequence of protecting alleged victims, the Court further permitted pseudonyms for several witnesses that were not alleged victims themselves “because the disclosure of their identities would necessarily reveal the identities of the alleged victims.” /d. at 8. These reasons for granting the Government’s prior motion do not apply to the Defense’s present request. Based on the current proffer, none of the Defense’s witnesses intend to testify to sensitive personal topics or sexual conduct. Rather, they all are anticipated to deny misconduct by Epstein and Ms. Maxwell, and therefore do not qualify as victims under § 3771. Further, there is no similar concern, as there are for alleged victims of sexual abuse, that denying the use of pseudonyms will deter reports of misconduct. It is notable that the Defense does not cite in support of its motion a single case in which a court granted the use of pseudonyms to defense witnesses. Neither does the Government. And nor could the Court after significant independent research. It appears, then, that the Defense’s DOJ-OGR- 00008388