Ckiask 2C2Ore3(11033030,443N nareaurnenn432 Filetill1/812721 Pajtigk C1163 7 U.S. Department of .1 u 'dice United States Attorney Southern District ofNew York USDC SDNY DOCUMENT ELECTRONICALLY PILED DOC 0: DATE FILED:11/11/21 The Silvio Mono Building One Saint Andrew's Plaza New Yin*. New York 10007 November 10, 2021 BY EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: The parties are ORDERED to submit the lists referenced in this letter on or before November 14, 2021, in accordance with Dkt. No. 427. The parties may continue submitting proposed redactions in accordance with the procedures this Court has previously set. SO ORDERED. United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) 11/11/21 Dear Judge Nathan: At the November I, 2021 pretrial conference, the Court directed the parties to file a joint letter regarding protections for witness identities at trial. In particular, the Court directed the parties to: (1) provide nomenclature for witnesses whose identities should be protected, (2) propose procedures for voir dire related to witness identities, (3) submit a proposed instruction to the jury regarding witnesses testifying under pseudonyms or under their first name only, and (4) address the logistics of offering sealed or redacted exhibits containing personal identifying information. Below are the positions of the parties regarding these logistical considerations. Because this letter contains identifying information relating to victims, the Government respectfully requests that the Court accept the Government's proposed redactions to this letter. Government position: I. Nomenclature With respect to nomenclature for witnesses whose identities should be protected at trial, the Government respectfully submits the following chart, which provides the true names of witnesses and the proposed nomenclature for those witnesses at trial. EFTA02834