A joint letter submitted to Judge Alison J. Nathan by the U.S. Attorney's Office and Defense Counsel in the case of United States v. Ghislaine Maxwell. The document outlines agreed-upon procedures and disagreements regarding the protection of witness identities during the upcoming trial, including the use of pseudonyms, voir dire protocols to screen jurors, specific jury instructions, and the use of physical binders for sealed exhibits to prevent public viewing. It includes a heavily redacted chart meant to map true witness names to their trial pseudonyms.
This document is a page from a legal filing dated October 29, 2021, which argues for victim protections during testimony. It cites two judicial precedents: one from Judge Garaufis, who distinguished between a victim's choice to speak publicly and court testimony, and another from Judge Donnelly in the case of *United States v. Robert Kelly*, where the court allowed victims to use pseudonyms due to the sensitive nature of their testimony about sexual abuse.
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