DOJ-OGR-00005405.pdf

--- Page 1 --- **Case 1:20-cr-00330-PAE** **Document 380** **Filed 10/29/21** **Page 12 of 54** **Case 1:20-cr-00330-PAE** **Document 380** **Filed 10/29/21** **Page 12 of 54** The Government also requests that two witnesses ("Witness-1" and "Witness-2"), who the Government expects will testify at trial about Minor Victim-1, be permitted to testify under pseudonyms. This request is a corollary of the protection requested for Minor Victim-1: Witness-1 is Witness-2 is The Government requests that Minor Victim-4 be permitted to testify using her first name only, and that two witnesses ("Witness-3" and "Witness-4"), who the Government anticipates will testify about Minor Victim-4, also be permitted to testify using their first names. Further, the Government requests that Minor Victim-6, who will not testify at trial, be referred to in open court by her first name only. Finally, the Government asks that the Court: (1) limit references at trial for the above Minor Victims and witnesses to the manner described above, including in jury addresses and **11**