DOJ-OGR-00008202.pdf

Case 1:20-cr-00330-PAE Document 519 Filed 11/30/21 Page 1 of 3 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagliuca@hmflaw.com November 30, 2021 VIA ECF 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, I write following our conferral with the government about protecting the anonymity of certain testifying witnesses in this case. The government suggested to us that we must avoid any public mention of: (1) names of people, places, or specific addresses or locations; (2) particular dates of career events or life events; (3) names of any employers, particular performances, or characters played; (4) specific details of story arcs in any performances played; (5) references to publicly available information or publicly available records that contain a pseudonymous witness's real name; and (6) court filings or other court documents. Respectfully, the government's proposal is overly broad and unworkable. We are mindful of the Court's orders on this topic, and we have no objection to many of the government's suggestions—e.g., the names of people or specific addresses or particular employers. But the government's proposal reaches much too far, and it would unfairly constrain Ms. Maxwell's ability to meaningfully and effectively confront her accusers. U.S. Const. amend. VI. DOJ-OGR-00008202