Giuffre v. Maxwell

Opinion

Case 1:15-cv-07433-LAP Document 1315 Filed 12/18/23 Page 1 of 51

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA GIUFFRE, Plaintiff, 15 Civ. 7433 (LAP) -against- ORDER GHISLAINE MAXWELL, Defendant.

LORETTA A. PRESKA, Senior United States District Judge: The Court reiterates here its previous recitation of the applicable law and descriptions of the unsealing process set out in the transcripts dated January 19, 2021 (dkt. no. 1196), July 1, 2021 (dkt. no. 1220), April 19, 2022 (dkt. no. 1254), and November 18, 2022 (dkt. no. 1283). The following are the Court’s findings as to the Does designated following its particularized review of the documents noted: Relevant .

This material should be unsealed in full. First, “[t]he burden of demonstrating that a document submitted to a court should be sealed rests on the party seeking such action.” DiRussa v. Dean Witter Reynolds Inc., 121 F.3d 818, 826 (2d Cir. 1997). No one has raised any objection to unsealing, and thus no “particular and specific demonstration of fact showing that disclosure would result in an injury” has been made that is sufficient to “overcome the presumption of access.” Lytle 235-13, 249-13, | v. JPMorgan Chase, 810 F. Supp. 2d 616, 630 (S.D.N.Y. 2011). Second, this individual gave a J. DOE 003 | 280-1, 321-1, | media interview about his or her work for Epstein to the Daily Mail in 2011, weighing against 423-4 continued sealing. United States v. Avenatti, No. (S1) 19 CR. 373 (PGG), 2020 WL 70952, at *6 (S.D.N-Y. Jan. 6, 2020) (“In considering whether sealing is appropriate, an important consideration is, of course, whether the information sought to be kept confidential is already public.”); 4/19/22 Hearing Tr. at 7:11-16 (unsealing documents relating to Doe who gave media interviews and was identified in the press); see https://www.dailymail.co.uk/news/article-1365733/How-Prince- Andrew-shared-room-Epsteins-Caribbean-hideaway-busty-blonde-claimed-brain-surgeon.html.

This material should be unsealed in full. First, no interests that outweigh the presumption of access have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 235-13, 249-13, ae . . □ 1 004 | 280-1. 321-1. Second, this individual gave a media interview about his or her work for Epstein to the Daily Mail 43-4. «| 2 2011, weighing against continued sealing. Avenatti, 2020 WL 70952, at *6; 4/19/22 Hearing Tr. at 7:11-16; see □□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□ shared-room-Epsteins-Caribbean-hideaway-busty-blonde-claimed-brain-surgeon.html.

Relevant .

This material should be unsealed in full. First, this mdividual did not raise any objection to unsealing, and thus did not meet his or her burden of identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, this individual testified publicly at Maxwell’s criminal trial, weighing against continued 315, 316-7, sealing. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25 (unsealing documents J. DOE 005 340-4, 368, relating to Doe whose name came up publicly at Maxwell criminal trial). Although this individual 369-3 testified under his or her first name only, he or she publicly waived any right to anonymity after the criminal trial, as Judge Nathan found, and gave an interview using his or her first and last names. See United States v. Maxwell, 20-cr-330, Dkt. nos. 589, 593, 662; https://www.dailymail.co-uk/news/article- 10380333/Key-witness-Ghislaine-Maxwells-trial- waives-anonymity-makes-sensational-new-claim.html.

203, 211, 235-4, | This material should be unsealed in full. Furst, this individual did not raise any objection to 235-13, 249-4, | unsealing, and thus did not meet his or her burden of identifying interests that outweigh the I. DOE 006 249-14, 280-1, | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 321-1, 380, Second, portions of this individual’s deposition were released by the Second Circuit, meaning his 381-4, 423-1, | or her name and association with this case is already public. Avenatti, 2020 WL 70952, at *6; 510-4 7/1/21 Hearing Tr. at 6-7 (ruling that materials released by the Second Circuit should be unsealed).

This material should be unsealed in full. First, this mdividual did not raise any objection to 338, 338-1, unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 338-9, 369-12, | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. DOE 007 397, 398, 398-5, | Second, portions of this individual’s deposition were released by the Second Circuit, meaning his 468, 469, 469-2, | or her name and association with this case is already public. Avenatti, 2020 WL 70952, at *6; 479, 514-5, 7/1/21 Hearing Tr. at 6-7 (ruling that materials released by the Second Circuit should be unsealed). 660-1 This individual’s name and relationship to Epstein were also publicly discussed at Maxwell’s criminal trial.

This material should be unsealed in full. First, no interests that outweigh the presumption of access have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 144-6, 173-6, | Second, this individual gave a media interview about his or her interactions with Epstein to Vanity J. DOE 008 | 249-13, 369-1, | Fair in 2020, weighing against continued sealing. Avenatti, 2020 WL 70952, at *6; 4/19/22 407-9, 423-4 | Hearing Tr. at 7:11-16 (unsealing documents relating to Doe who gave media interviews and was identified in the press); see https://www.vanityfair.com/news/2020/12/confessions-of-a- clintonworld-exile.

122-4, 173-6, 180-1, 180-3, 235-13, 280-1, 321-1, 321-2, 321-3, 321-4, 338, 338-3, 346-4, 369-1, . oe ae . 384-1. 388 This material should be unsealed in full. First, this individual did not raise any objection to 389-8 392. 307. unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 398-1 466. presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 009 , Second, documents relating to this individual, including emails on which the individual is copied 467-1, 467-2, - 481. 482. 48-1. and a substantive declaration by the individual, were released by the Second Circuit, meaning his 482-3 4189- 4 > | or her name and association with this case Is already public. Avenattt, 2020 WL 70952, at *6; 637. 638. 638-1. 7/1/21 Hearing Tr. at 6-7 (ruling that materials released by the Second Circuit should be unsealed). 638-2, 638-3, 638-4, 638-5, 653, 654, 654-1, 660-3, 697, 698, 698-1, 698-2, 754

173-6, 180-3, . oe ae . 346-4. 369-1 This material should be unsealed in full. First, this individual did not raise any objection to DOEOI0| 38 AL 430-7, unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 638-1. 698-1. presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 698-2 ° Second, the sealed material as to this individual is not salacious.

173-6, 249-13, | This material should be unsealed in full. First, no interests that outweigh the presumption of access 280-1, 321-1, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 011 340-3, 340-4, | Second, this individual’s association with Epstein has been reported in the media already, and his 363-7, 369-1, | or her name came up at Maxwell’s public criminal trial. Avenatti, 2020 WL 70952, at *6; 11/18/22 423-4 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, this individual did not raise any objection to 49-13. 321-1 unsealing, and thus did not meet his or her burden of identifying interests that outweigh the DOE 013 321-5 371-6 * | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 3 63-7 493- A Second, this individual’s association with Epstein has been reported in the media already, and his , or her name came up at Maxwell’s public criminal trial. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 014 340-4 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the sealed material as to this individual is not salacious.

Doe 15’s name shall remain redacted in the document at docket number 363-7. The unsealing of Doe 15’s name in this document would disclose sensitive information regarding an alleged minor victim of sexual abuse who has not spoken publicly and who has maintained his or her privacy. 49-13. 280-1. As such, the public interest does not outweigh the privacy interests of the alleged minor victim. J. DOE 015 32 oe Otherwise, this material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet his or her burden of identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures. In addition, this individual gave a press interview in 2011.

150-1, 172, 173-6, 229-2, 249-13, 321-1, 321-5, 321-6, | Doe 16’s name and any identifying information shall remain sealed. Doe 16 is an alleged minor J. DOE 016 339, 340-3, victim of sexual abuse who has not spoken publicly and who has maintained his or her privacy. As 340-4, 363-7, | such, the public interest does not outweigh the privacy interests of the alleged minor victim. 369-1, 400, 401-5, 423-4, 450-1

This material should be unsealed in full. First, no interests that outweigh the presumption of access have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 018 381-3 Second, this individual’s name appears only in an already publicly available police report, and the individual appears to be a member of law enforcement (specifically, an assistant state attorney). Finally, the only document that substantively discusses this individual is already publicly available on the docket with this individual’s name unredacted. See dkt. no. 1199-10.

180-2. 203. 211 This material should be unsealed in full. First, this individual did not raise any objection to 73 5-10 335-13. unsealing, and thus did not meet his or her burden of identifying interests that outweigh the J. DOE 019 49-14 280-1 , presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 321-1 ° 363-7 > | Second, this individual’s role in this case has been reported in the media already. Avenatti, 2020 ° WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, this individual did not raise any objection to DOE 020 656-2. 947-1 unsealing, and thus did not meet his or her burden of identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, as to Docket Entry 656-2, this is a publicly available news article.

This material should be unsealed in full. This individual did not raise any objection to unsealing, and thus did not meet his or her burden of identifying interests that outweigh the presumption of J. DOE 021 435 access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. This individual is a public figure, and the only insinuation is that his or her name was contained, along with many others, in an Epstein address book. There is no salacious allegation about him contained in the sole document.

This material should be unsealed in full. First, no interests that outweigh the presumption of access have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 022 701-1, 947-1 Second, this individual’s association with Epstem has been reported in the media already. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. This individual is a public figure, and none of the materials that relate to him are salacious.

150-1, 160, 165-3, 172, 173-5, 173-6, 185-2, 185-3, 185-11, 189, 203, 211, 224, 229, 229-2, 235-4, 247-3, 249-4, 249-13, . . □□ 272-3. 280-1. This material should be unsealed in full. This individual s role in Epstein S Sex trafficking has J. DOE 023 316-6, 320. been widely reported in the media > the Second Circuit unsealed alle gations about this individual in 321-1. 321-2 this case, and he or she was subject to widely publicized criminal prosecution abroad for sex 321-3. 321-4. trafficking. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. 321-5, 321-6, 339, 340-3, 363-7, 369-1, 369-2, 369-14, 369-15, 407-9, 408-1, 423-4, 641-1, 655, 700, 701-1, 714

J DOE 024 46. 247-1 This material should be unsealed in full. The sealed material as to this individual 1s not salacious. ° Indeed, these documents have already been made public by Professor Dershowitz and this Court.

This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 025 | 235-13, 381-3 | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the only document that substantively discusses this individual is already publicly available on the docket with this individual’s name unredacted. See dkt. no. 1199-10.

This material should be unsealed in full. First, no interests that outweigh the presumption of access I. DOE 026 381-3 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the only document that substantively discusses this individual is already publicly available on the docket with this individual’s name unredacted. See dkt. no. 1199-10.

This material should be unsealed in full. First, no interests that outweigh the presumption of access 249-13, 280-1, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 027 | 321-1, 369-10, | Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 423-4 disclosures. Third, this individual’s association with Epstein has been reported in the media already. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, no interests that outweigh the presumption of access I. DOE 029 363-7 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the only reference is a deposition answer that this individual was a staff member possibly present at a time and place.

This material should be unsealed in full. First, this individual did not raise any objection to I DOE 030 340-4 unsealing, and thus did not meet his or her burden of identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the sealed material as to this individual is not salacious.

This material should be unsealed in full. First, no interests that outweigh the presumption of access I DOE 031 35-4. 405-] have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. ° Second, the sealed material as to this individual is not salacious. The only references to this individual are in passing and in a benign context.

This material should be unsealed in full. First, no interests that outweigh the presumption of access 173-5, 185-11, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 032 | 235-4, 363-7, | Second, this individual’s association with Epstein has been widely reported in the media already, 369-10, 656-2 | and the Second Circuit unsealed this individual’s name and information about his or her relationship with Epstein. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-235.

173-6, 235-13, 249-13, 280-1, | This material should be unsealed in full. First, no interests that outweigh the presumption of access DOE 033 321-1, 321-5, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 321-6, 340-3, | Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 340-4, 369-1, | disclosures. 423-4

This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 034 701-1 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. sown] bart ara 231, 249-13, 280-1. 32]-]. | This material should be unsealed in full. First, no interests that outweigh the presumption of access I. DOE 035 321-5. 321-6. have been identified with specificity. DiRussa, 121 F.3d at 826, Lytle, 810 F. Supp. 2d at 630. 340- 4 35 5-2. Second, the sealed material as to this individual is not salacious and mostly relate to deposition 403-4 > | scheduling.

144-6, 173-5, 173-6, 180-1, 180-6, 203, 211, 224, 228, 229-4, 235-4, 235-13, 246. 247-1. This material should be unsealed in full. First, this individual did not raise any objection to 972-5. 272-6. unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 1 DOE 036 | 280-1, 307-8. presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 320. 321-1. Second, this individual’s association with Epstein and Maxwell has been widely reported in the 3 31-2 3 313 media already, and his or her name came up at Maxwell’s public criminal trial. Avenatti, 2020 391-4. 391-6, WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. 339, 340-1, 340-3, 354, 355-2, 363, 363-1, 363-7, 364, 368, 369-1,

Relevant . 369-2, 369-10, 378, 388, 389-9, 407-6, 407-8, 407-9, 423-1, 423-4, 435, 450-1, 471-1, 510-4, 632-1, 656-2, 657, 947-1

173-6, 180-1, | This material should be unsealed in full. First, this individual did not raise any objection to 180-6, 185-3, | unsealing, and thus did not meet his or her burden of identifying interests that outweigh the I. DOE 037 249-13, 272-5, | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 369-1, 388, Second, the sealed materials all relate to the same two facts about this individual’s association with 389-9, 407-18, | Maxwell, which is not salacious and has been widely reported in the media already. Avenatti, 423-4 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, this mdividual did not raise any objection to I. DOE 038 272-5, 320, unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 407-21, 947-1 | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the sealed material about this individual is not salacious.

This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 039 423-1,510-4, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 656-2 Second, this individual is a journalist who investigated Epstein, and thus his or her materials should all be unsealed.

This material should be unsealed in full. First, no interests that outweigh the presumption of access 172, 173-5, have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 040 | 407-6, 407-8, | Second, this individual’s association with Epstein has been reported in the media already, and in 407-9, 450-1 fact certain of the sealed documents at issue are news articles. Avenatti, 2020 WL 70952, at *6: 11/18/22 Hearing Tr. at 6:19-25.

349-13. 321-1 This material should be unsealed in full. First, no interests that outweigh the presumption of access , 5. * | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J.DOE 041 | 321-5, 321-6, 2°. 493-4 Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures and lists of search terms.

249-13, 280-1, This material should be unsealed in full. First, this individual did not raise any objection to 321-1. 321-5 unsealing, and thus did not meet his or her burden of identifying interests that outweigh the J. DOE 042 321-6. 363-7. presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. > | Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 423-4 disclosures.

Doe 43’s name and any identifying information shall remain sealed. Doe 43 is an alleged minor 1. DOE 043 700. 701-1 victim of sexual abuse who has not spoken publicly about the subject matter of this litigation and ° who has maintained his or her privacy. As such, the public interest does not outweigh the privacy interests of the alleged minor victim.

This material should be unsealed in full. First, no interests that outweigh the presumption of access 249-13, 280-1, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. DOE 044 321-1, 321-5, | Second, this individual’s allegations against Epstein and others have been previously reported on 321-6, 363-7, | by the press, and this individual has given multiple interviews to the media. Avenatti, 2020 WL 369-10, 423-4 | 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25; see https://www-.nbcnews.com/news/us-news/how- british-teen-model-was-lured-jeffrey-epstein-s-web-n1056901.

This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 247-1, 249-13, | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 045 | 280-1, 321-1, | Second, this individual’s allegations against Epstein and others have been previously reported on 321-5, 423-4 | by the press, and this individual has given multiple interviews to the media. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25; see https://www.gloriaallred.com/wp- content/uploads/sites/1200518/2021/01/2019-08-27-Epstein-Teala-Davies.pdf.

This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 046 258-3 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the sealed material as to this individual is not salacious.

This material should be unsealed in full. First, no interests that outweigh the presumption of access have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. DOE 047 32-9. 235-8 Second, this individual’s name appears only in an already publicly available police report released ° by the Second Circuit, and the individual appears to be a member of law enforcement (specifically, a detective). Finally, the only document that substantively discusses this individual is already publicly available on the docket with this individual’s name unredacted. See dkt. no. 1199-10.

349-13. 280-1. | This material should be unsealed in full. First, no interests that outweigh the presumption of access 321-1 391-5 * | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 048 3 31-6 339 "| Second, this individual’s allegations against Epstein and others have been previously reported on 4 3 4 , by the press, and this individual testified publicly at a hearing before Judge Berman after Epstein’s death. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. This dividual has advocated to this Court that all J. DOE 049 passim . materials relating to him or her should be unsealed. See, e.g., dkt. no. 1138.

DOE 050 69 This material should be unsealed in full. This individual is a medical provider whose name has already been revealed in unredacted documents on the docket. See, e.g., dkt. no. 1256-19.

249-13. 280-1 This material should be unsealed in full. First, no interests that outweigh the presumption of access , 5. * | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J.DOE051 | 321-1, 321-5, 2°, Se | | Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 321-6, 423-4 . ; disclosures and lists of search terms.

150-1. 173-6. | _ iis material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 052 ° ° have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 340-3, 369-1 oo. Second, the sealed material as to this individual is not salacious.

235-13, 249-13, 280-1, 321-1, | Doe 57’s name and any identifying information shall remain sealed. Doe 57 is an alleged victim J. DOE 057 | = 321-5, 321-6, | of sexual abuse who has not spoken publicly and has maintained his or her privacy. As such, the 338, 338-6, public interest does not outweigh the privacy interests of the alleged victim. 423-4

Doe 58’s name and any identifying information shall remain sealed. Doe 58 is a classic outsider, I. DOE 058 947-1 peripheral to the events at issue. Doe 58 is neither a victim nor associated with Epstein or Maxwell. Any reference to Doe 58 played no apparent role in Judge Sweet’s ruling on the motion to which this document was attached.

1. DOE 059 235-10, 380, | This material should be unsealed in full. This individual is deceased but his or her name was 423-1,510-4 | unsealed in materials released by the Second Circuit.

249-13. 280-1. This material should be unsealed in full. First, no interests that outweigh the presumption of access I DOE 061 321-1. 321-5. have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 321- 6 493- A Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 , disclosures.

This material should be unsealed in full. The parties were unable to locate an address for this individual, and therefore no notice was provided (dkt. no. 1116, { 7). However, the sealed material as to this individual is not salacious. J. DOE 062 258-3 The material will redact the name of Doe 84, whose identity the Second Circuit kept sealed. Releasing Doe 84’s name could harm the privacy interests of the individual the Court of Appeals deemed sealable by allowing the press and others to identify the deponent’s identity.

144-4. 144-6. | This material should be unsealed in full. First, this individual did not raise any objection to 1 50-1. 173-6. unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 935-13. 249-13. presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 1 DOE 063 | 315. 330. 3 40-3. Second, this individual’s allegations against Epstein and others have been previously reported on 3 4 0-4 , 368 > | by the press, this individual has given multiple interviews to the media, and this individual testified , ; publicly at Maxwell’s criminal trial under his or her real name. Avenatti, 2020 WL 70952, at *6; 369-1, 423-4, | 11/18/22 Hearing Tr. at 6:19-25; https://www-.nytimes.com/2019/08/26/us/epstein-farmer-sisters- 845, 856 maxwell html.

This material should be unsealed in full. First, this mdividual did not raise any objection to 280-1. 315. unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 316-7. 321-1. presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 064 □ | Second, this individual’s allegations against Epsteim and others have been previously reported on 339, 340-4, 368, □□ ge ae . . 369-3. 845. 856 by the press, and this individual has given multiple interviews to the media. Avenatti, 2020 WL ° > 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25; https://www.nytimes.com/2019/08/26/us/epstein- farmer-sisters-maxwell html.

172, 173-5, This material should be unsealed in full. First, this individual did not raise any objection to 235-13, 249-13, | unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 1. DOE 065 280-1, 321-1, | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 321-5, 321-6, | Second, this individual’s association with Epstein has been widely reported in the media already, 407-6, 423-4, | and the Second Circuit unsealed this individual’s name and information about his or her 493-1 relationship with Epstein. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

235-4, 235-13, I. DOE 066 280-1, 316-7, | This material should be unsealed in full. No interests that outweigh the presumption of access have 321-1, 340-4, | been identified with specificity. DiRussa, 121 F.3d at 826: Lytle, 810 F. Supp. 2d at 630. 369-3, 381-1

203, 211, 235-4, | This material should be unsealed in full. First, no interests that outweigh the presumption of access 235-13, 249-13, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 067 249-14, 257, Second, portions of this individual’s deposition were released by the Second Circuit, meaning his 258, 258-3, or her name and association with this case is already public. Avenatti, 2020 WL 70952, at *6; 258-4, 258-9, 7/1/21 Hearing Tr. at 6-7. During the criminal trial, one of the named victims testified that Plaintiff 261, 267, 268, | and this individual, who were then both over the age of 18, recruited him or her at the age of 14 to

Relevant . 268-2, 280-1, | provide massages to Epstein. This Doe’s first and last name were provided in open court in 307-8, 315, 316, | connection with these allegations. See Trial Tr. 1517, 1743 (U.S. v. Maxwell, 20-cr-330). 316-2, 316-7, 321-1, 321-5, 321-6, 339, 340, 340-4, 340-8, 363-7, 368, 369, 369-3, 369-4, 381-3, 388, 389, 389-4, 392, 393, 393-1, 400, 401, 401-6, 423-1, 423-4, 450-1, 510-4, 513, 845, 856

This material should be unsealed in full. First, no interests that outweigh the presumption of access DOE 068 340-4 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, this individual’s association with this case has been reported in the media already. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

172, 173-6, 203, 211. 224. 229-6 This material should be unsealed in full. First, no interests that outweigh the presumption of access v4 4 * | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 069 | 249-4, 249-13, ae ; . . . ve ees eee ? ? Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. 435, 607-3

228, 235-13, J. DOE 070 280-1, 307-8, | This material should be unsealed in full. No interests that outweigh the presumption of access have 321-1, 339, 363, | been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 364, 406, 435

This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 071 249-13, 321-5, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 321-6, 423-4 Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures.

949-13. 280-1. | This material should be unsealed in full. First, no interests that outweigh the presumption of access , 5. * | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 072 | 321-1, 321-5, = oO Second, the sealed material as to this individual 1s not salacious and consists primarily of Rule 26 321-6, 423-4 . , disclosures.

232-7, 232-9, 235-4, 235-8, . . DOE 075 | 235-10. 235-13 This material should be unsealed in full. No interests that outweigh the presumption of access have 307-8. 363-7 * | been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 423-1

This material should be unsealed in full. No interests that outweigh the presumption of access have J. DOE 076 450-1 been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. This individual’s name also appears in a publicly available police report.

173-5, 173-6, | This material should be unsealed in full. First, this individual did not raise any objection to 340-5, 354, unsealing, and thus did not meet his or her burden of identifying interests that outweigh the J. 077 355-2, 363-7, | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 369-1, 378, Second, this individual’s association with Epstein has been widely reported in the media already, 408-1, 423-1, | and the Second Circuit unsealed this individual’s name and information about his or her 435, 510-4 relationship with Epstein. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, no interests that outweigh the presumption of access I. DOE 078 assim have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. P Second, the Second Circuit unsealed this individual’s name and information about his or her relationship with Epstein. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

249-13, 280-1, J. DOE 079 321-1, 321-5, | This material should be unsealed in full. No interests that outweigh the presumption of access have 321-6, 340-4, | been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 423-4

This material should be unsealed in full. First, no interests that outweigh the presumption of access 080 | 249-13, 423-4 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures.

655, 656-7, This material should be unsealed in full. This individual did not raise any objection to unsealing, J. DOE 081 656-8, 701-1, | and thus did not meet his or her burden of identifying interests that outweigh the presumption of 714 access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630.

249-13, 280-1, 280-2, 321-1, | This material should be unsealed in full. First, this individual did not raise any objection to 321-5, 321-6, | unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 338-9, 398-5, | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 082 | 423-4, 450-1, | Second, this individual’s name and association with Epstem and Maxwell has been widely 450-5, 655, publicized by the media, this individual has been named as a defendant in public lawsuits relating 656-4, 656-8, | to Epstem, and the Second Circuit unsealed substantial material relating to this individual. 700, 701-1, 928, | Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. 947-1, 957

235-13, 280-1, . . . . 1. DOE 083 391-1. 423-1 This material should be unsealed in full. No interests that outweigh the presumption of access have 510-4 > | been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630.

172, 203, 211, 224, 228, 229, 229-11, 231, 235-13, 249-4, 249-13, 257, . cee . □ 258. 258-3. 26). | Doe 84’s name and any identifying information shall remain sealed. Doe 84 is an alleged victim J. DOE 084 80-1. 321-1. ‘| of sexual abuse who has not spoken publicly and who has maintained his or her privacy. As such, 321- 4 321- 5 the public interest does not outweigh the privacy interests of the alleged victim. 321-6, 423-4, 567, 568, 568-4, 606, 631, 632, 632-1

This material should be unsealed in full. First, no interests that outweigh the presumption of access 1. DOE 085 340-4 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the only reference is a deposition question in answer to which the deponent denied knowledge of the individual.

235-13, 249-13, I. DOE 086 280-1, 321-1, | This material should be unsealed in full. No interests that outweigh the presumption of access have 321-5, 321-6, | been identified with specificity. DiRussa, 121 F.3d at 826: Lytle, 810 F. Supp. 2d at 630. 363-7, 423-4

173-6, 180-1, oe. 2. 369-1. 423-1 This material should be unsealed in full. This individual passed away in 2018. But this individual’s J. DOE 087 435 5 10-4 "| association with Epstein has been widely reported in the media already, along with pictures of this 656 5 , individual on Epstein’s island. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, no interests that outweigh the presumption of access have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 088 340-4 — . Second, the only reference is a deposition question in answer to which the deponent denied knowledge of the individual.

This material should be unsealed in full. First, this individual did not raise any objection to 235-13, 249-13, | unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 280-1, 321-1, | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 089 321-5, 321-6, Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 340-4, 369-10, | disclosures and lists of search terms. Finally, this individual’s name and association with Epstein 423-4 has been publicized by the media. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

173-6. 340-3 This material should be unsealed in full. This individual did not raise any objection to unsealing, J. DOE 090 3 69-1 "| and thus did not meet his or her burden of identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630.

249-13, 280-1, | This material should be unsealed in full. This individual did not raise any objection to unsealing, J. DOE 091 321-1, 321-5, | and thus did not meet his or her burden of identifying interests that outweigh the presumption of 321-6, 423-4 | access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630.

Any information about this individual should be unsealed in full. First, this dividual did not raise any objection to unsealing, and thus did not meet his or her burden of identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the sealed material as to this individual is not salacious and consists mostly of J. DOE 092 | None Identified | privilege logs and documents discussing privilege logs. Finally, this individual’s name and association with Epstein has been widely publicized by the media, this individual has been named as a defendant in public lawsuits relating to Epstem, and the Second Circuit unsealed this individual’s name and information about his or her relationship with Epstein. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 093 701-1 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the sealed material as to this individual is not salacious.

This material should be unsealed in full. This individual did not raise any objection to unsealing, J. DOE 094 235-4 and thus did not meet his or her burden of identifying interests that outweigh the access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630.

This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet his or her burden of identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. I. DOE 095 338-9. 398-5 Second, the sealed material as to this individual is not salacious. Finally, this individual’s name ° and association with Epstein has been widely publicized by the media and this individual has been named as a defendant in public lawsuits relating to Epstein. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25 (unsealing documents relating to Doe who “has been the subject of intense media coverage”).

This material should be unsealed in full. This individual did not raise any objection to unsealing, J. DOE 096 576 and thus did not meet his or her burden of identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630.

J. DOE 098 340-4 This material should be unsealed in full. First, no interests that outweigh the presumption of access have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630.

Relevant . Second, the only reference is a deposition question to which the deponent denied knowledge of the Doe.

This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet his or her burden of identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 099 passim Second, this individual’s name and association with Epsteim and Maxwell has been widely publicized by the media, this individual has been named as a defendant in public lawsuits relating to Epstem, and the Second Circuit unsealed substantial material relating to this individual. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, no interests that outweigh the presumption of access DOE 100 340-4 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the only reference is a deposition question to which the deponent denied knowledge of the Doe.

This material should be unsealed in full. First, this individual did not raise any objection to 235-13, 280-1, | unsealing, and thus did not meet his or her burden of identifying interests that outweigh the J. DOE 101 321-1, 423-1, | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 510-4 Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures and lists of search terms.

This material should be unsealed in full. First, this individual did not raise any objection to 1 DOE 102 280-2, 338-9, | unsealing, and thus did not meet his or her burden of identifying interests that outweigh of access 398-5 with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, this individual’s name and association with Epstein has already been publicized by the media.

This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet his or her burden of identifying interests that outweigh the DOE 103 | 235-13. 363-7 presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. , Second, this individual’s association with Epstein has been widely reported in the media already, and the Second Circuit unsealed this individual’s name and information about his or her relationship with Epstein. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

Plaintiff acknowledged that this person is deceased and therefore did not receive notice. The Court J. DOE 104 247-1 is unable to locate Doe’s name in the listed pleading. Accordingly, any material relating to this Doe should be unsealed in full.

249-13, 280-1, . . □□□ 321-1. 321-5. This material should be unsealed in full. This individual did not raise any obj ection to unsealing, J. DOE 106 321- 6. 423- 4 and thus did not meet his or her burden of identifying interests that outweigh the presumption of 435 > | access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630.

This material should be unsealed in full. This individual did not raise any objection to unsealing, J. DOE 108 701-1 and thus did not meet his or her burden of identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630.

This material should be unsealed in full. First, this individual did not raise any objection to 185-3, 363, unsealing, and thus did not meet his or her burden of identifying interests that outweigh the J.DOE 109 | 450-1, 450-5, | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 568-3 Second, this individual’s name and association with Epstein has already been widely publicized by the media. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

173-6, 249-13, 280-1. 32]-]. | This material should be unsealed in full. First, this individual did not raise any objection to 321-5. 32]-6. unsealing, and thus did not meet his or her burden of identifying interests that outweigh the J. DOE 110 : ‘| presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 339, 340-3, □□ ge gag . Second, this individual’s name and association with Epstein has been widely publicized by the 340-4, 363-7, | media. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. 369-1, 423-4

249-13, 280-1, | This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 111 321-1, 321-5, have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 321-6, 423-4 | Second, the sole references appear to be in Rule 26 disclosures and search terms.

235-13, 249-13, | This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 112 280-1, 321-1, have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 423-4 Second, the sole references appear to be in Rule 26 disclosures and search terms.

249-13, 280-1, | This material should be unsealed in full. First, no interests that outweigh the presumption of access 1 DOE 113 321-1, 321-5, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 321-6, 423-4, | Second, the references all are included in Rule 26 disclosures, search terms, and a hearsay 435 statement that the name appears in Epstein’s address book.

This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 114 173-6, 369-1 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the sole reference is that this individual’s name appears to be contained on a flight log.

This material should be unsealed in full. First, no interests that outweigh the presumption of access 1 DOE 115 435 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. - Second, the sealed material as to this individual is not salacious; the sole reference to this individual is a hearsay statement that the Doe appeared in Epstein’s address book.

398-4. 338 This material should be unsealed in full. First, this individual did not raise any objection to 1 DOE 116 338-8 168. unsealing, and thus did not meet his or her burden of identifying interests that outweigh the , presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 469-1, 660-1 Co . Second, the sealed material as to this individual is not salacious.

This material should be unsealed in full. This individual is a former law enforcement official and, J.DOE117 | 450-1,471-1 | specifically, a former Assistant U.S. Attorney, and this individual’s role in the Epstein case is part of a public Office of Professional Responsibility Report.

249-13. 280-1], | This material should be unsealed in full. First, no interests that outweigh the presumption of access , * | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J.DOE118 | 321-1, 321-5, □ 321-6. 423-4 Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 ~ disclosures.

249-13. 280-1. | This material should be unsealed in full. First, this individual did not raise any objection to 321-1 321-5 | unsealing, and thus did not meet his or her burden of identifying interests that outweigh the J. DOE 119 32 1-6. 340-4. presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 4 3-4 > | Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures.

This material should be unsealed in full. First, no interests that outweigh the presumption of access 576, 655, 656-4, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 1. DOE 120 656-5, 656-6, | Second, this individual’s name and association with Epstein and Maxwell has been widely 656-7, 700, publicized by the media and this individual has been named as a defendant in public lawsuits 701-1, 947-1 relating to Epstem. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25 (unsealing documents relating to Doe who “has been the subject of intense media coverage”).

This material should be unsealed in full. First, no interests that outweigh the presumption of access have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. DOE 121 381-1 Second, this individual’s name appears only in an already publicly available police report, and the individual appears to be a member of law enforcement (specifically, a police officer). Finally, the only document that substantively discusses this individual is already publicly available on the docket with this individual’s name unredacted. See dkt. no. 1199-8.

150-1, 173-6, 203, 211, 224, 235-4, 280-1, 320, 321-1, This material should be unsealed in full. First, no interests that outweigh the presumption of access 321-6, 340-3, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 122 340-4, 369, Second, this individual’s name and association with Epstem and Maxwell has been widely 369-1, 407, publicized by the media and this individual has been named as a defendant in public lawsuits 407-9, 655, relating to Epstein. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. 656-, 656-6, 656-9, 700, 701-1, 701-2

J. DOE 123 260-2, 270-6, | This material should be unsealed. This individual is a medical provider whose name has already 272-9 been revealed in documents on the docket, unredacted. See dkt. no. 1090-45.

Doe 124’s name and any identifying information shall remain sealed. Doe 124 1s a classic outsider, 1. DOE 124 701-1 peripheral to the events at issue. Doe 124 is neither a victim nor associated with Epstein or Maxwell. Any reference to Doe 124 played no apparent role in Judge Sweet’s ruling on the motion to which this document was attached.

935-13. 249-]3. | This material should be unsealed in full. Plaintiff sent a non-party notice to this individual and 780-1 321-] □ | received delivery confirmation. First, this individual did not raise any objection to unsealing, and J. DOE 125 VIL 5. 21- 6. thus did not meet his or her burden of identifying interests that outweigh the presumption of access 403 4 > | with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, this individual’s name and association with Epstein has been publicized by the media. Avenatti.

249-13. 280-1 This material should be unsealed in full. First, no interests that outweigh the presumption of access , 5. * | have been identified with specificity. DiRussa, 12] F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J.DOE 126 | 321-1, 321-5, □□□ ; . 321-6. 423-4 Second, this individual’s name and association with Epstein has been publicized by the media. ° Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

235-13. 280-1 This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 127 301-1 * | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, this individual’s name appears in a publicly available police report.

249-13, 280-1, | This material should be unsealed in full. This individual did not raise any objection to unsealing, J.DOE 128 | 321-1, 321-5, | and thus did not meet his or her burden of identifying interests that outweigh the presumption of 321-6, 423-4 access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630.

249-13, 280-1, | This material should be unsealed in full. This individual did not raise any objection to unsealing, J.DOE 129 | 321-1,321-5, | and thus did not meet his or her burden of identifying interests that outweigh the presumption of 321-6, 423-4 | access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630.

This material should be unsealed in full. First, this mdividual did not raise any objection to unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 1 DOE 130 450-1. 471-1 presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. , Second, this individual is a former law enforcement official and, specifically, a former Assistant US. Attorney, and this individual’s role in the Epstein case is part of a public Office of Professional Responsibility Report.

203, 211, 232, 235, 235-7, This material should be unsealed in full. First, no interests that outweigh the presumption of access 235-13, 249-4, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 131 | 258-10, 280-1, | Second, portions of this individual’s deposition were released by the Second Circuit, meaning his 320, 321-1, 368, | or her name and association with this case is already public. Avenatti, 2020 WL 70952, at *6; 369, 369-8, 392, | 7/1/21 Hearing Tr. at 6-7. 393, 393-1

173-5, 173-6, 235-13, 280-1, 321-1, 321-5, . □□□ ae . 321-6. 340-5. This material should be unsealed in full. Allegations about this individual have been widely J. DOE 132 3 63-7. 3 69-1. reported in the media, and the Second Circuit unsealed allegations about this individual in this ° > | case. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. 435, 450-1, 510-3, 514-3, 701-1

173-5, 235-3, | This individual’s name and identifying information shall remain sealed in full. Plaintiff does not 247-1, 249-13, | dispute that this Doe was mistakenly identified in a photograph and that this Doe’s characterization J. DOE 133 280-1, 321-1, | as an alleged perpetrator was first introduced by a reporter, not by Plaintiff. In addition, this Doe 407-6, 435, has sought to avoid public attention to the allegations. As such, the public interest does not 450-1, 701-1 outweigh the privacy interests of this Doe.

173-6, 228, . . . . 249-13. 280-1 This material should be unsealed in full. First, no interests that outweigh the presumption of access , * | have been identified with specificity. DiRussa, 12] F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 134 | 321-1, 321-5, ae □ □ 321-6. 369-1 Second, this individual’s name and association with Epstein and Maxwell has been publicized by 403 4 > | the media. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

173-6, 235-13, | Doe 135’s name and any identifying information shall remain sealed. Doe 135 is an alleged minor 135 | 321-5, 321-6, | victim of sexual abuse who has not spoken publicly and who has maintained his or her privacy. 340-3, 369-1 As such, the public interest does not outweigh the privacy interests of the alleged minor victim.

This individual is the same individual as Doe 157. This material should be unsealed in full. First, 184, 185-3, this individual did not raise any objection to unsealing, and thus did not meet his or her burden of 249-13, 280-1, | identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d 1. DOE 136 321-1, 321-5, | at 826; Lytle, 810 F. Supp. 2d at 630. Second, this individual’s name and association with Epstein 321-6, 406, 407, | and Maxwell has been widely publicized by the media and this individual has been named as a 408, 408-1, defendant in public lawsuits relating to Epstem. Avenatti, 2020 WL 70952, at *6; 11/18/22 423-4, 435 Hearing Tr. at 6:19-25 (unsealing documents relating to Doe who “has been the subject of intense media coverage”).

DOE 137 363-7 This material should be unsealed in full. Plaintiff located no address for this person, but the only reference is a deposition question to which the Party denied knowledge of.

This material should be unsealed in full. This individual did not raise any objection to unsealing, and thus did not meet his or her burden of identifying interests that outweigh the presumption of J. DOE 138 381-1 access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Further, this individual’s name appears only in a public police report and was already released by this Court. See dkt. no. 1199-8.

This material should be unsealed in full. First, this mdividual did not raise any objection to 249-13, 280-1, . ae DOE 139 | 321-1. 321-5 unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 321-6 423-4 presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. ° Second, the Second Circuit unsealed this individual’s name and relationship with Epstein.

249-13. 280-1 This material should be unsealed in full. First, no interests that outweigh the presumption of access mon 2. * | have been identified with specificity. DiRussa, 12] F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J.DOE 140 | 280-2, 321-1, □□ a ; . . 403-4 Second, the Second Circuit unsealed this individual’s name and relationship with Epstein. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, no interests that outweigh the presumption of access DOE 141 249-13, 363-7, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 423-4 Second, the Second Circuit previously unsealed this individual’s name. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

228, 249-13, . . . 321-1. 321-5 This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 142 mae | have been identified with specificity. DiRussa, 12] F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 321-6, 340-4, 2 493-4 Second, the sealed material as to this individual is not salacious.

This material should be unsealed in full. First, no interests that outweigh the presumption of access have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 1. DOE 143 Second, this individual’s association with Epstein and Maxwell has been widely reported in the Passi media already, and his or her name came up at Maxwell’s public criminal trial. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. This individual was also named as a defendant in a public, federal lawsuit involving the same conduct underlying this action.

249-13, 321-1, 321-5, 321-6, | This material should be unsealed in full. First, this individual did not raise any objection to 1 DOE 145 368, 369, unsealing, and thus did not meet his or her burden of identifying interests that outweigh the ~ | 369-12, 423-4, | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 513, 514, 514-5, | Portions of this individual’s 2009 deposition in a matter against Epstem were also unsealed. 568-5, 607-3

This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 146 701-1 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the references are not salacious.

172, 173-5, This material should be unsealed in full. First, this mdividual did not raise any objection to 185-11, 228, | unsealing, and thus did not meet his or her burden of identifying interests that outweigh the DOE 148 235-4, 235-13, | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 249-13, 363-7, | Second, this individual’s association with Epstein and Maxwell has been widely reported in the 423-4, 435, media already, and his or her name was unsealed by the Second Circuit previously. Avenatti, 2020 450-1, 701-1 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, no interests that outweigh the presumption of access DOE 149 173-5 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Further, this individual is a law enforcement official, and the only information in the transcript about this individual is not salacious.

This material should be unsealed in full. First, no interests that outweigh the presumption of access have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 150 229-1 Second, the deposition of this individual’s spouse was released with redactions by this Court and previously by the Second Circuit, and the only information in the transcript about this individual is not salacious.

510-4 connection with this matter. Avenatti, 2020 WL 70952, at *6; 7/1/21 Hearing Tr. at 6-7.

203, 211, 235-4, This material should be unsealed in full. First, no interests that outweigh the presumption of access 935-13. 249-4. have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. | Second, this individual has given statements and interviews to the media in connection with this J. DOE 153 | 280-1, 321-1, . ae ea as □ 338. 493-1. matter, and portions of this individual’s deposition were released by the Second Circuit. Avenatti, , ; 2020 WL 70952, at *6; 7/1/21 Hearing Tr. at 6-7; https://www.youtube.com/watch?v=Wq- 423-4,510-4 JY

173-6, 249-13, | This material should be unsealed in full. First, this individual did not raise any objection to 258-4, 280-1, | unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 321-1, 321-5, | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 154 | 321-6, 340-3, | Second, this individual’s allegations against Epstein and others have been previously reported on 340-4, 369-1, | by the press, and this individual has given interviews to the media. Avenatti, 2020 WL 70952, at 423-4, 450-1, *6; 11/18/22 Hearing Tr. at 6:19-25; https://people.com/crime/woman-who-recruited-girls-for- 482-4 jeffrey-epstem-as-teen-rape-survivor-i-was-confused-when-he-died/.

Al

172, 173-6, 203, 211, 224, 229-12, 249-4, | This material should be unsealed in full. First, no interests that outweigh the presumption of access 249-13, 368, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 155 369, 369-1, Second, this individual testified publicly at Maxwell’s criminal trial, weighing against continued 369-2, 369-13, | sealing. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. Portions of this 388, 389, 389-5, | individual’s deposition in this matter were also unsealed by the Second Circuit. 389-6, 392, 393, 393-1, 423-4

152, 153-7, 172, 173-6, 185-3, 247-1, 249-13, 339, 340-3, 340-4, 363-7, 368, 369, 369-1, oo, 369-16. 379-3. This material should be unsealed in full. This person’s deposition in a prior Epstein-related matter J. DOE 156 406 407 407-1 is publicly available, and portions of that deposition were unsealed by the Second Circuit. > > > | Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. 407-8, 408, 408-1, 423-4, 435, 450-1, 567, 568, 568-5, 606, 607, 607-3, 631, 656-2, 721-1

This individual is the same individual as Doe 136. This material should be unsealed in full. First, 249-13, 321-5, | this individual did not raise any objection to unsealing, and thus did not meet his or her burden of 321-6, 338, identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d DOE 157 338-9, 398-5, | at 826; Lytle, 810 F. Supp. 2d at 630. Second, this individual’s name and association with Epstein 407, 407-9, and Maxwell has been widely publicized by the media and this individual has been named as a 423-4, 450-1, | defendant in public lawsuits relating to Epstein. Avenatti, 2020 WL 70952, at *6; 11/18/22 450-5, 660-1 Hearing Tr. at 6:19-25 (unsealing documents relating to Doe who “has been the subject of intense media coverage”).

This material should be unsealed in full. First, this mdividual did not raise any objection to 173-6, 369-1, | unsealing, and thus did not meet his or her burden of identifying interests that outweigh the J. DOE 158 235-13, 320, | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 450-1 Second, this individual’s relationship with Epstein has been widely publicized by the media. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

1. DOE 159 701-1 This material should be unsealed in full. No interests that outweigh the presumption of access have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630.

been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630.

This material should be unsealed in full. This individual’s name appears in a publicly available J. DOE 161 381-1 police report, and the only document that substantively discusses this individual is already publicly available on the docket with this individual’s name unredacted. See dkt. no. 1199-10.

143, 144-6, 150-1, 172, 173, 173-5, 173-6, 189, 203, 204, 204-1, 211, 212, This material should be unsealed in full. First, this individual did not raise any objection to 212-1, 224, unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 247-1, 249-4, presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 1 DOE 162 249-13, 257, Second, this individual’s allegations against Epstein and others have been previously reported on 258, 258-2, 261, | by the press, this individual gave an interview to the Daily Mail in 2021, and the Second Circuit 272-7, 280-1, | unsealed substantial information relating to this individual. Avenatti, 2020 WL 70952, at *6; 315, 316, 316-1, | 11/18/22 Hearing Tr. at 6:19-25; https:/www.dailymail.co.uk/news/article-10357057/Key-figure- 316-6, 316-8, | case-against-Prince-Andrew-former-student-claims-met-Epstein-mansion.html. 321-1, 321-5, 321-6, 338, 338-1, 338-7, 339, 340, 340-3, 340-4, 340-5,

Relevant . 340-6, 363-7, 368, 369, 369-1, 369-2, 369-5, 378, 388, 389, 389-1, 392, 393, 393-1, 400, 401, 401-3, 401-4, 423-4, 450-6, 492, 493, 493-1, 568-5, 660-3, 845, 856

316-7. 340-4 Doe 164’s name and any identifying information shall remain sealed. Doe 164 is an alleged minor J. DOE 164 3 6 9-3 > | victim of sexual abuse who has not spoken publicly and who has maintained his or her privacy. As such, the public interest does not outweigh the privacy interests of the alleged minor victim.

This material should be unsealed in full. First, this individual did not raise any objection to DOE 165 340-4 unsealing, and thus did not meet his or her burden of identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the sealed material as to this individual is not salacious.

173-5. 173-6. | This material should be unsealed in full. First, this individual did not raise any objection to 340-3. 340-4. | Unsealing, and thus did not meet his or her burden of identifying interests that outweigh the : | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 166 | 363-7, 369-1, oe . . . . > | Second, this individual’s association with Epstein and Maxwell has been widely reported in the 369-10, 407-6, a ; oo. . . media already, and his or her name came up during Maxwell’s public criminal trial. Avenatti, 435, 632-1 | 9920 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

173-6, 249-13, 280-1, 321-1, | This material should be unsealed in full. This individual did not raise any objection to unsealing, 167 | 321-5, 321-6, | and thus did not meet his or her burden of identifying interests that outweigh the presumption of 363-7, 369-1, | access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 423-4

235-13, 249-13, . . 980-1. 321-1. This material should be unsealed in full. Furst, no interests that outweigh the presumption of access J. DOE 168 321-5. 321-6. have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 4 3-4 > | Second, all references to this person are either Rule 26 disclosures or search terms.

This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet his or her burden of identifying interests that outweigh the J. DOE 169 363-7, 435 presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, this individual’s association with Epstein has been widely reported in the media already. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, no interests that outweigh the presumption of access 1. DOE 170 229-10, 450-3, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 482-4 Second, emails contaming this individual’s name and association with Epstein were previously unsealed by this Court. Third, the sealed material as to this individual is not salacious.

This material should be unsealed in full. First, this mdividual did not raise any objection to 1 DOE 172 173-6. 369-1 unsealing, and thus did not meet his or her burden of identifying interests that outweigh the ° presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the sealed material as to this individual is not salacious.

This material should be unsealed in full. First, no interests that outweigh the presumption of access 1 DOE 173 235-13, 280-1, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 321-1, 381-3 Second, the only document that substantively discusses this individual is already publicly available on the docket with this individual’s name unredacted. See dkt. no. 1199-10.

173-5. 340-5 This material should be unsealed in full. First, no interests that outweigh the presumption of access 363-7. 407-6. have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 174 , | Second, this individual’s association with Epstein and Maxwell has been widely reported in the 435, 656-2, 657, oe . 701-1. 947-1. media already, and his or her name came up during Maxwell’s public criminal trial. Avenatti, ee 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, no interests that outweigh the presumption of access 173-6, 340-3, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J.DOE 175 | 340-4, 369-1, | Second, this individual’s association with Epstein and Maxwell has been widely reported in the 369-10 media already, and his or her name came up during Maxwell’s public criminal trial. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, no interests that outweigh the presumption of access I. DOE 176 249-13, 321-5, | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 321-6, 423-4 | Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures.

935-4. 235-13 This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 177 aa, * | have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 423-1, 510-4 oo . Second, the sealed material as to this individual is not salacious.

Doe 178’s name and any identifying information shall remain sealed. Doe 178 is an alleged minor J. DOE 178 258-3, 568-4 | victim of sexual abuse who has not spoken publicly and who has maintained his or her privacy. As such, the public interest does not outweigh the privacy interests of the alleged minor victim.

173-8, 340-6, | This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 179 400, 401-3, have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. 450-6 Second, this individual’s name was unsealed in materials released by the Second Circuit.

This is the same individual as Doe 181, and the deposition examiner mistakenly used the incorrect name in the deposition transcripts at issue. This material should be unsealed in full. First, no 173-6. 340-3 interests that outweigh the presumption of access have been identified with specificity. DiRussa, J. DOE 180 369-1 * | 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, this individual testified publicly at Maxwell’s criminal trial, weighing against continued sealing. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. Portions of this individual’s deposition in this matter were also unsealed by the Second Circuit.

173-6, 249-13, 280-1, 280-2, This material should be unsealed in full. First, no interests that outweigh the presumption of access 321-1. 321-5 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. J. DOE 181 321- 6. 3 63-7. Second, this individual testified publicly at Maxwell’s criminal trial, weighing against continued , | sealing. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. Portions of this Oe individual’s deposition in this matter were also unsealed by the Second Circuit.

This material should be unsealed in full. First, no interests that outweigh the presumption of access J. DOE 182 340-4 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the only reference to this individual is in a deposition question that was never answered.

This material should be unsealed in full. First, no interests that outweigh the presumption of access I. DOE 184 435 have been identified with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, this individual’s association with Epstein has been reported in the media already. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

This material should be unsealed in full. First, this mdividual did not raise any objection to unsealing, and thus did not meet his or her burden of identifying interests that outweigh the 235-13. 249-13. presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. DOE 185 321-1. 321-5. | Second, this individual’s allegations against Epstein and others have been previously reported on 32 1- 6 473- A by the press, this individual has given multiple interviews to the media, and this individual has ° been a plaintiff in public lawsuits relating to Epstein’s sex trafficking. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25; https:/www.cbsnews.com/news/jeffrey-epstein-accuser- speaks-today-livestream-2019-07-16/.

This material should be unsealed in full. First, this mdividual did not raise any objection to 235-13. 280-1. unsealing, and thus did not meet his or her burden of identifying interests that outweigh the J. DOE 186 321-1 | presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures and lists of search terms.

249-13. 280-1. This material should be unsealed in full. First, this individual did not raise any objection to 321-1. 321-5. unsealing, and thus did not meet his or her burden of identifying interests that outweigh the J. DOE 187 321-6. 407-9. | Presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 630. ° > | Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 423-4 disclosures and lists of search terms.

The Court stays its order for fourteen days to permit any impacted Doe the opportunity to appeal, after which counsel are asked to confer, prepare the documents for unsealing pursuant to this order, and post the documents on the docket. SO ORDERED. Dated: December 18, 2023 New York, New York

LORETTA A. PRESKA Senior United States District Judge