DOJ-OGR-00006533.pdf

--- Page 1 --- **Document Header** * **Case Number:** 1:20-cr-00330-PAE * **Document Number:** 440 * **Filed Date:** 11/12/21 * **Page Number:** 17 of 40 **Main Text** There is every reason to believe that, if the Court orders that Minor Victims be permitted to testify under pseudonyms, many major publications will honor that request and not rebroadcast the Minor Victim's names should they surface elsewhere. The Government does not assume that the mainstream press would reveal the identity of a victim against her wishes, particularly if the victim is testifying under Court-ordered protections to preserve her anonymity. Furthermore, the Government's understanding from conferring with prosecutors in similar cases is that the mainstream press did not, in fact, reveal the identities of victims who testified under court-ordered protections. And in any event, even marginally reduced exposure is significant to the Minor Victims. There is a very meaningful difference between the names of victims appearing in some dark corner of the internet, and the names of the victims appearing in the news outlets that will be viewed by the friends, families (including children), and employers of the Minor Victims. D. The Defendant Has No Countervailing Interests at Stake, Much Less a Particularized Need for Disclosure. In the context of the disclosure of witness identifying information, the Second Circuit has identified two primary interests of defendants: "(1) obtaining information needed for in-court and out-of-court investigation of the witness; and (2) enabling defense counsel to elicit information **Footer** * **DOJ-OGR-00006533** **Page Number** * **16**