DOJ-OGR-00006520.pdf

--- Page 1 --- The extracted text is: **PRELIMINARY STATEMENT** The Government respectfully submits this memorandum of law in further support of its October 18, 2021 motions in limine. **ARGUMENT** **I. The Court Should Permit Certain Witnesses to Testify Under Pseudonyms or Using First Names, and Permit the Sealing of Related Exhibits** The Government seeks limited, narrowly tailored relief to protect the victims in this case. Certain of the Minor Victims have not publicly identified themselves as victims of child sexual abuse by the defendant and Jeffrey Epstein, or have not done so in the same level of detail as they are expected to provide at trial. Consistent with the Crime Victims' Rights Act, see 18 U.S.C. § 3771(a)(8), and the regular practice in this District and the Eastern District, (see Gov't Mot. at 6-8 (citing twelve cases)), the Government asks the Court to permit those Minor Victims to testify using either pseudonyms or first names, and for related relief regarding other witnesses and exhibits to protect the identities of the same Minor Victims. To the extent this request presents logistical concerns, they are readily solvable in this case, as they were in United States v. Kelly, No. 19 Cr. 286 (AMD) (E.D.N.Y.), United States v. Raniere, No. 18 Cr. 204 (NGG) (E.D.N.Y.), and numerous other recent sex trafficking trials, including high-profile sex trafficking trials and ones in which victims had made prior public statements. The Government has not sought to withhold the identities of the Minor Victims from the defense or the jury, so this request has no effect whatsoever on the defendant's right to a fair trial. The defendant's primary response is to **Case 1:20-cr-00330-PAE Document 440 Filed 11/12/21 Page 4 of 40**