DOJ-OGR-00005409.pdf

--- Page 1 --- **Document Header** * Case Number: 1:20-cr-00330-PAE * Document Number: 380 * Filed Date: 10/29/21 * Page Number: 16 of 54 **Text** Public disclosure of victim information is unnecessary. The defendant already knows the true identity of all six Minor Victims, Witness-1, Witness-2, Witness-3, and Witness-4. The defense is therefore fully able to complete an investigation in advance of trial. Indeed, defense investigators have contacted many of the victims and witnesses at issue in this motion already. The defense will then be able to use that information on cross-examination. And, because the jury will know the Minor Victims' true names, the defense is free to make every argument, including by reference to the general occupation and living situation of the Minor Victims or witnesses. But there is no need—much less a particularized need—for the victims' true names or other personal identifying information to be stated in open court to accomplish that purpose. In sum, the identifying information the Government seeks to limit in open court, including the full names of the victims and witnesses, specific employment and family information, is largely irrelevant to their testimony. There is a substantial risk, however, that Public disclosure of these names is also not necessary for jury selection. At voir dire, prospective jurors can be given a sheet of paper with the true names and pseudonyms of the protected witnesses and asked whether they know any individuals on the paper. Accordingly, the Court and parties may screen for juror bias without requiring any juror to state a protected name in open court. The Government has no objection to cross-examination of Minor Victim-1, Minor Victim-3, and Witness-2 on The defense should be precluded from eliciting such details. **Footer** * DOJ-OGR-00005409