Case 1:20-cr-00330-PAE Document 717 Filed 07/12/22 Page1of10
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
My 150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
[email protected]
HADDON
MORGAN
FOREMAN
December 12, 2021
VIA Email
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re: — United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan,
As directed, I write to request that the Court permit three witnesses called by the defense
to testify using pseudonyms or their first names only. Those witnesses are J, Michelle
Healy, and yg. Ms. Maxwell submits this letter at the request of these witnesses.!
Ms. Maxwell has conferred with the government about this request. The government
opposes any form of protective anonymity for these witnesses.
BACKGROUND
So far, there have been ten trial days in this case. During that time, several witnesses have
testified using a pseudonym or their first name only. These witnesses include three of the four
alleged victims (Jane, Kate, and Carolyn) and two other government witnesses (Matt and
' Ms. Maxwell may call as witnesses individuals who share the same true last name as the
alleged victims in this case. Consistent with this Court’s earlier ruling, and subject to her earlier
objections, Ms. Maxwell does not oppose these witnesses testifying using pseudonyms or their
first names only.
DOJ-OGR-00011320