[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` The Honorable Alison J. Nathan December 12, 2021 Page 4 Ms. Maxwell expects her to testify on Monday, December 20. This Court should permit to testify using a pseudonym. First, has a substantial professional interest in testifying using a pseudonym. Put simply, is justifiably worried that she will be denounced and ostracized by her colleagues should it become a matter of public record that she testified at the request of Ms. Maxwell’s defense team. See, e.g., United States v. Marti, 421 F.2d 1263, 1266 (2d Cir. 1970) (proper for court to preclude defense from revealing witness’s address when that information “may subject the witness to reprisals”). Her testimony in this case, if revealed, presents a real threat to her employment. See United States v. Marcus, No. 05 CR 457 (ARR), 2007 WL 330388, at *1 (E.D.N.Y. Jan. 31, 2007) (pseudonymity may be appropriate “to avert loss of employment potentially resulting from trial publicity”). Cf. TR 11/1/2021, p 8:1-3 ``` | OBJECTS: The image contains text and a page number (Page 4 of 10). | SETTING: The setting appears to be a legal document or court filing, as indicated by the reference to a court date and the formal language used. | ACTIVITY: The activity depicted is a legal argument or motion regarding the use of a pseudonym for a witness. | NOTABLE: The document discusses the potential risks and benefits of using a pseudonym for a witness, particularly in cases where the witness's identity could lead to reprisals or job loss. It references previous court cases to support its arguments.