EFTA00028260.pdf

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pdf

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data-set-8

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U.S. Department of Justice 
United States Attorney 
Southern District of New York 
The Si viol 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 (MN) 
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: ( I) 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: 
Nomenclature
I. 
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. 
EFTA00028260


Page 2 
The Government submits that this nomenclature can be used when trial begins on 
November 29, 2021, but that the parties should be directed to continue referencing victims and 
witnesses on the public record according to the nomenclature in the Superseding Indictment. The 
Government further requests that the defense be directed to redact the true names of the witnesses 
in this char…

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