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Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page1of8
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
December 14, 2021
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, S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in opposition to the defendant’s request to
permit three witnesses to testify using pseudonyms or first names. The defendant’s unprecedented
request seeks relief for an issue that arises in a large number of cases, and that relief is not necessary
to protect the defendant’s constitutional rights. Accordingly, the Government opposes the motion.
1. Applicable Law
It is “firmly established” that “the press and general public have a constitutional right of
access to criminal trials.” Globe Newspaper Co. v. Superior Court for Norfolk County, 457 U.S.
596, 603 (1982); see United States v. Alcantara, 396 F. 3d 189, 194-95 (2d Cir. 2005) (describing
the “qualified First Amendment right to attend trials”).
It is well settled that the names of certain categories of trial witnesses can be withheld from
DOJ-OGR-00011233