DOJ-OGR-00006442.pdf

--- Page 1 --- The extracted text is: **Header** Case 1:20-cr-00330-PAE Document 439 Filed 11/12/21 Page 25 of 69 **Main Text** 17 (2) alleged minor victims who are truly minors at the time of their testimony18; and (3) alleged victims who demonstrated legitimate safety concerns.19 **Footers** 18 Mot. at 7 United States v. Corley, No. 13-CR-48 (AJN), 2016 WL 9022508, at *1 (S.D.N.Y. Jan. 15, 2016)(minor victim after trial). 19 Mot. at 5, United States v. Marti, 421 F.2d 1263, 1265 (2d Cir. 1970)(The government claims this case involved the identity of the witness, which is not true. The only issue was the address of the witness, "Pelletier" identified in the opinion: "Since counsel could not insure that Pelletier or his family would not be harassed, it was perhaps not unreasonable for them to view as too costly the court's condition on allowing Pelletier to answer." Id.); United States v. Urena, 8 F. Supp. 3d 568 (S.D.N.Y. 2014)(allegations of racketeering, murder, and narcotics trafficking identity of officers suppressed); United States v. Cavallaro, 553 F.2d 300, 304 (2d Cir. 1977)(kidnapping, witness was threatened and was in witness protection program-only address of witness, not identity was restricted); Mot. at 7, United States v. Dan Zhong, No. 16-CR-614 (DLI), 2018 WL 6173430, at *1 (E.D.N.Y. Nov. 26, 2018)(victims of the alleged forced labor conspiracy-concerns for safety) **Page Number** 17