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Case 1:20-cr-00330-PAE Document 432 Filed 11/10/21 Page1of5
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
November 10, 2021
BY EMAIL
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint
letter regarding protections for witness identities at trial. In particular, the Court directed the
parties to: (1) provide nomenclature for witnesses whose identities should be protected, (2) propose
procedures for voir dire related to witness identities, (3) submit a proposed instruction to the jury
regarding witnesses testifying under pseudonyms or under their first name only, and (4) address
the logistics of offering sealed or redacted exhibits containing personal identifying information.
Below are the positions of the parties regarding these logistical considerations. Because this letter
contains identifying information relating to victims, the Government respectfully requests that the
Court accept the Government’s proposed redactions to this letter.
Government position:
I. Nomenclature
With respect to nomenclature for witnesses whose identities should be protected at trial,
the Government respectfully submits the following chart, which provides the true names of
witnesses and the proposed nomenclature for those witnesses at trial.
DOJ-OGR-00006333