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Case 1:20-cr-00330-PAE Document548- Filed 12/15/21 Page3of6 requested relief is unprecedented. The Defense raises several specific arguments in favor of its unprecedented request. First, the Defense argues that anonymity is necessary to protect its witnesses from scrutiny and harassment because of the significant publicity this case has garnered. But these generalized concerns are present in every high-profile criminal case. They do not present the rare circumstances that prior courts have found justify the use of pseudonyms. Further, the alleged victims that received pseudonyms during the Government’s case have a statutory right to have their “dignity and privacy” protected. 18 U.S.C. § 3771(a)(8). The Defense’s witnesses have no similar right. Perhaps most analogous to Defendant’s request is United States v. Rainiere, United States v. Rainiere, No. 18-CR-204S1 (NGG), 2021 WL 4522298 (E.D.N.Y. Oct. 4, 2021), another high-profile case involving alleged sexual misconduct. There, after a defendant pled guilty, the defense sought to keep letters submitted in support of the defendant at sentencing anonymous, arguing that anonymity was necessary because “the authors of supportive letters may face retribution if their identities are publicly known, given the public attention that has been paid to this case” and that failure to do so “will have a chilling effect on individuals who wish to speak in support of defendants in other high-profile prosecutions.” /d. at *3-4. The court 2 6¢ acknowledged the individuals’ “genuine interest in assisting sentencing while remaining out of the public eye themselves,” but concluded that their letters about the defendant did “not involve traditionally private matters” and that the public’s interest in access prevailed. /d. at *4. The Court concludes that the same analysis applies here. Second, and relatedly, the Defense argues that without pseudonyms, its witnesses may refuse to testify, implicating Ms. Maxwell’s right to present a defense. The Court notes the late- DOJ-OGR-00008389