Page 1 of 7
Cétash: 2Q20rOCRR eB AON Dacunrent42 Aréelinyim771 Paétege afct 7
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
ae = One Saint Andrew’s Plaza
USDC SDNY New York, New York 10007
DOCUMENT
ELECTRONICALLY FILED
DOC #; November 10, 2021
DATE FILED: 11/11/21
BY EMAIL
The parties are ORDERED to submit the lists
The Honorable Alison J. Nathan referenced in this letter on or before November 14,
United States District Court 2021, in accordance with Dkt. No. 427. The parties
Southern District of New York may continue submitting proposed redactions in
United States Courthouse accordance with the procedures this Court has
40 Foley Square previously set. SO ORDERED.
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Ale \) ls 4/11/21
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-00006353