Draft: efta02790287

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 003	235-13, 249-13, 280-1, 321-1, 423-4	Employee of Epstein; Alleged Witness	<p>Plaintiff: 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." <i>DiRussa v. [REDACTED] Witter [REDACTED] Inc.</i>, 121 F.3d 818, 826 (2d Cir. 1997). This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying "with specificity competing and compelling interests in closure" and that "those interests outweigh the presumption of access." <i>Lytle v. JPMorgan Chase</i>, 810 F. Supp. 2d 616, 621 (S.D.N.Y. 2011). Second, this individual gave a media interview about their work for Epstein to the Daily Mail in 2011, weighing against continued sealing. <i>United States v. Avenatti</i>, 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); <i>see</i> [REDACTED]</p> <p>[REDACTED]</p> <p>[REDACTED]</p> <p>[REDACTED]</p> <p>Defendant: All docket mentions are Rule 26 disclosures. This individual and Doe #4 reportedly live abroad and no confirmation of receipt of the Notice was received.</p>
J. DOE 004	235-13, 249-13, 280-1, 321-1, 423-4	Employee of Epstein; Alleged Witness	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, this individual gave a media interview about their work for Epstein to the Daily Mail in 2011, weighing against continued sealing. <i>Avenatti</i>, 2020 WL 70952, at *6; 4/19/22 Hearing Tr. at 7:11-16; <i>see</i> [REDACTED]</p> <p>[REDACTED]</p> <p>[REDACTED]</p>

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
			Defendant: All mentions are Rule 26 disclosures and search terms. This individual and Doe #3 reportedly live abroad and no confirmation of receipt of the Notice was received.
J. DOE 005	315, 316-7, 340-4, 368, 369-3	Alleged Victim; Alleged Witness	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, this individual testified publicly at Maxwell's criminal trial, weighing against continued sealing. <i>Avenatti</i>, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25 (unsealing documents relating to Doe whose name came up publicly at Maxwell criminal trial). This individual, however, testified under their first name only with Judge Nathan's permission. Plaintiff therefore has no objection to the redaction of this individual's last name in documents that are not already public.</p> <p>Defendant objects to redaction of this Doe's last name. The witness publicly waived any right to anonymity after the criminal trial, as Judge Nathan found, and gave an interview using their first and last names, so no legal basis to redact last name remains. <i>See United States v. Maxwell</i>, 20-cr-330, Dkt. 589, 593, 662;</p> <p>[REDACTED]</p> <p>[REDACTED]</p> <p>[REDACTED]</p>
J. DOE 006	203, 211, 235-4, 235-13, 249-4, 249-14, 280-1, 321-1, 380, 381-4, 423-1, 510-4	Alleged Victim Affiliate; Alleged Witness	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, portions of this individual's deposition were released by the Second Circuit, meaning their name and association with this case is already public. <i>Avenatti</i>, 2020 WL 70952, at *6; 7/1/21 Hearing Tr. at 6-7 (ruling that materials released by the Second Circuit should be unsealed).</p> <p>Defendant: Confirmation of receipt of Notice received.</p>

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 007	338, 338-1, 338-9, 369-12, 397, 398, 398-5, 468, 469, 469-2, 479, 514-5, 660-1	Employee of Epstein	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, portions of this individual's deposition were released by the Second Circuit, meaning their name and association with this case is already public. <i>Avenatti</i>, 2020 WL 70952, at *6; 7/1/21 Hearing Tr. at 6-7 (ruling that materials released by the Second Circuit should be unsealed). This individual's name and relationship to Epstein were also publicly discussed at Maxwell's criminal trial.</p> <p>Defendant: Confirmation of receipt of Notice received.</p>
J. DOE 008	144-6, 173-6, 249-13, 369-1, 407-9, 423-4	Alleged Epstein Affiliate	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, this individual gave a media interview about their interactions with Epstein to Vanity Fair in 2020, weighing against continued sealing. <i>Avenatti</i>, 2020 WL 70952, at *6; 4/19/22 Hearing Tr. at 7:11-16 (unsealing documents relating to Doe who gave media interviews and was identified in the press); <i>see</i> [REDACTED]</p> <p>Defendant: No confirmation of receipt of Notice received.</p>

Relevant P seudonym
Docket Entries Characterization 122-4, 173-6, 180-1, 180-3, 235-13,280-1, 321-1, 321-2,	Additional Comments/Argument
321-3, 321-4,	Plaintiff: This material should be unsealed in full. First, this individual did not
338, 338-3, 346-	raise any objection to unsealing, and thus did not meet their burden of
4, 369-1, 384-1,	identifying interests that outweigh the presumption of access with specificity.
388, 389-8, 392,	DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, documents
397, 398-1, 466, Alleged Witness;	relating to this individual, including emails on which the individual is copied
J. DOE 009 467-1, 467-2, Alleged Maxwell	and a substantive declaration by the individual, were released by the Second
481, 482, 482-1,	Employee Circuit, meaning their name and association with this case is already public.
482-3, 482-4,	Avenatti, 2020 WL 70952, at *6; 7/1/21 Hearing Tr. at 6-7 (ruling that materials
637, 638, 638-1, 638-2, 638-3,	released by the Second Circuit should be unsealed).
638-4, 638-5, 653, 654, 654-1, 660-3, 697, 698, 698-1, 698-2,	Defendant: Confirmation of receipt of Notice received.
173-6, 180-3,	identifying interests that outweigh the presumption of access with specificity.
3464, 369-1, Alleged Witness;	DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Further, this individual
J. DOE 010 384-1, 482-2, Alleged	ii
638-1, 698-1,	Employee them, and still raised no objection to unsealing after receiving those excerpts Maxwell
698-2	Second, the sealed material as to this individual is not salacious. received.

Pseudonym	R elevant
	Docket Entries	Characterization	Additional Comments/Argument
	173-6, 249-13,		identifying interests that outweigh the presumption of access with specificity.
	280-1, 321-1'		DiRussa, 121 F.3d at 826; Lvtle, 810 F. Stipp. 2d at 621. Second, this
J. DOE 011	340-3, 340-4,	Alleged Epstein	individual's association with Epstein has been reported in the media already.
	363-7, 369-1.	Affiliate	and their name came up at Maxwell's public criminal trial. Avenatti, 2020 WL
	423-4		70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.
	249-13, 321-	Employee of	DiRussa, 121 F.3d at 826; Lvtle, 810 F. Supp. 2d at 621. Second, this
J. DOE 013	1, 321-5, 321-6,	Epstein; Alleged	individual's association with Epstein has been reported in the media already, and
	363-7, 423-4	Witness; Alleged	their name came up at Maxwell's public criminal trial. Avenatti, 2020 WL
		Perpetrator	70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.
J. DOE 014	34o- 1	Alleged Epstein
			any knowledge of individual. No confirmation of receipt of Notice was

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
	249-13, 280-1, 321-1, 363-7, 423-4	Alleged Victim Affiliate	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures.</p> <p>Defendant: This individual gave a press interview in 2011 publicly denying that Epstein had been alone with Doe # 16, who she mentioned by name and whose photograph is contained in the article. The article was produced by Plaintiff in this action at Giuffre003394 and was broadcast over the Web to millions of users. [REDACTED] [REDACTED] (the article appears to have been removed from the internet but a copy of Plaintiff's produced version can be provided to the Court upon request).</p> <p>All redacted references are R. 26 disclosures, search terms, and a deponent who denied ever meeting individual. Confirmation of receipt of Notice was received.</p>
J. DOE 015	150-1, 172, 173-6, 229-2, 249-13, 321-1, 321-5, 321-6, 339, 340-3, 340-4, 363-7, 369-1, 400, 401-5, 423-4, 450-1	Alleged Victim	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, this individual testified publicly at Maxwell's criminal trial, weighing against continued sealing. <i>Avenatti</i>, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25 (unsealing documents relating to Doe whose name came up publicly at Maxwell criminal trial). This individual, however, testified under a pseudonym with Judge Nathan's permission. Plaintiff therefore has no objection to the redaction of only this individual's name in documents that are not already public, but any relevant information about their allegations against Epstein and Maxwell should be unsealed because this individual revealed that information at trial publicly.</p>

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
			<p>Defendant: As an adult, this Doe voluntarily interviewed with the press about her allegations against Epstein.</p> <p>[REDACTED]</p> <p>[REDACTED]</p> <p>The Second Circuit has already released this Doe's entire name and details about her profession. Ex. KK to the summary judgment motion at pages 28 and 29.</p> <p>Ms. Maxwell objected to this witness testifying under a pseudonym at the criminal trial. <i>See</i> 20-cr-330, Dkt. 382 at pp. 4-23 (redacted). And for the same reasons objects to further "redaction of only this individual's name" as Plaintiff urges.</p>
J. DOE 018	381-3	Law Enforcement Officer	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. 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. <i>See</i> D.E. 1199-10.</p> <p>Defendant: No confirmation of receipt of Notice was received.</p>
J. DOE 019	180-2, 203, 211, 235-10, 235-13, 249-14, 280-1, 321-1, 363-7	Alleged Victim Affiliate	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, this individual's role in this case has been reported in the media already. <i>Avenatti</i>, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.</p> <p>Defendant: Confirmation of receipt of Notice was received.</p>

Pseudonym	Relevant	Characterization Docket Entries Additional Comments/Argument
J. DOE 020	656-2, 947-1	Alleged Witness
J. DOE 021	435	Alleged Epstein
J. DOE 022	701-1, 947-1	Alleged Epstein
		Affi bete

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 023	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, 316-6, 320, 321-1, 321-2, 321-3, 321-4, 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	Alleged Perpetrator; Alleged Epstein Affiliate; Alleged Witness	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, this individual is alleged to have engaged in serious wrongdoing, and it is generally the privacy interests of "innocent third parties," not those accused of serious misconduct, that "weigh heavily in a court's balancing equation." <i>United States v. Amodeo</i> , 71 F.3d 1044, 1050 (2d Cir. 1995). Finally, this individual's role in Epstein's sex trafficking has been widely reported in the media, the Second Circuit unsealed allegations about this individual in this case, and they were themselves subject to widely publicized criminal prosecution abroad for sex trafficking. <i>Avenatti</i> , 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. Defendant: This individual passed away. The alleged "role" the individual played was never adjudicated in any court and consists largely of unsworn statements by Plaintiff.
J. DOE 024	246, 247-1	Alleged Dershowitz Affiliate	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, the sealed material as to this individual is not salacious. Defendant: This particular document has already been made public by Professor Dershowitz and this Court. The individual has passed away. [REDACTED] [REDACTED]

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 025	235-13, 381-3	Alleged Victim Affiliate; Alleged Perpetrator	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, the only document that substantively discussing this individual is already publicly available on the docket with this individual's name unredacted. <i>See</i> D.E. 1199-10. Defendant: Confirmation of receipt of Notice was received.
J. DOE 026	381-3	Alleged Victim Affiliate	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, the only document that substantively discussing this individual is already publicly available on the docket with this individual's name unredacted. <i>See</i> D.E. 1199-10. Defendant: No confirmation of receipt of Notice received.
J. DOE 027	249-13, 280-1, 321-1, 369-10, 423-4	Alleged Epstein Affiliate	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures. Third, this individual's association with Epstein has been reported in the media already. <i>Avenatti</i> , 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. Defendant: No confirmation of receipt of Notice was received.

Pseudonym	Relevant
	Docket Entries	Characterization Additional Comments/Argument
1 DOI 029	363-7	Employee of
J. DOE 030	340- I	Alleged Epstein
J. DOE 031	2354' 405-1	Unknown'

For individuals characterized as "unknown," the parties have been unable to determine from the information available to them and the relevant docket entries how to accurately characterize the individual.¶

Pseudonym Relevant	(haracterization Docket Entries	Additional Comments/Argnment
		DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this 173-5, 185-11. individual's accoriation with Epstein has been widely reported in the media
J. DOE 032 235-4, 363-7,	Alleged Epstent	already, and the Second Circuit unsealed this individual's name and information
369-10, 656-2	Affiliate	about their relationship with Epstein. Avenatti, 2020 WL 70952, at *6; 11/18/22
173-6, 235-13,		raise any objection to unsealing, and thus did not meet their burden of
249-13, 280-1,		identifying interests that outweigh the presumption of access with specificity.
321-1, 321-5, 321-6, 340-3.	Alleged Epstein material as to this individual is not salacious and consists primarily of Rule 26 J. DOE 033 Affiliate	disclosures.
423-4		Defendant: The parties were unable to locate an address for this individual and
J j)(H 011	Defendant:	material as to this individual is not salacious.
	Affiliate	Defendant: No confirmation receipt of Notice received. The Doe was an

Relevant
Docket Entries Characterization Pseud" Yin	Additional Comments/Argument
231, 249-13,	raise any objection to unsealing, and thus did not meet their burden of
280-1, 321-1,	identifying interests that outweigh the presumption of access with specificity.
J. DOE 035 321-5, 321-6, Alleged Epstein	DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, the sealed
3404, 355-2,	Affiliate material as to this individual is not salacious and mostly relate to deposition
423-4 144-6, 173-5, 173-6, 180-1,	scheduling.
180-6, 203, 211,	Plaintiff This material should be unsealed in full. First, this individual did not
224, 228, 229-4,	raise any objection to unsealing, and thus did not meet their burden of
2354, 235-13,	identifying interests that outweigh the presumption of access with specificity.
246, 247- 1,	DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Further, this individual
272-5, 272-6,	actually requested excerpts of materials mentioning them, which the parties sent
280-1, 307-8,	them, and still raised no objection to unsealing after receiving those excerpts.
320, 321-1, 321- 2, 321-3, 321-4,	Second, this individual's association with Epstein and Maxwell has been widely
321-6, 339, 340- Alleged J. DOE 036	Epstein
1, 340-3, 354,	Affiliate 25.
355-2, 363, 363-	Defendant: The criminal trial testimony concerning the individual was limited
1, 363-7, 364,	to a single reference to a plane flight. The items that Plaintiff hopes to unseal
368, 369-1, 369-	contain a number of salacious, unproven allegations about this individual. Judge
2, 369-10, 378,	Sweet denied Plaintiff's efforts to depose the individual fmding the "relevance
388, 389-9, 407-	of testimony" of the individual has "not been adequately established." See
6, 407-8, 407-9,	Order of June 20, 2016 at 17. The individual was served with the Notice through
423-1, 423-4, 435, 450-1, 471- 1, 510-4, 632-1,	counsel.

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
	173-6, 180-1,		DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Further, this individual
	180-6, 185-3,		actually requested excerpts of materials mentioning them, which the parties sent
J. DOE 037	249-13, 272-5,	Alleged Maxwell	them, and still raised no objection to unsealing after receiving those excerpts.
	369-1, 388, 389-	Affiliate	Second, the sealed materials all relate to the same two facts about this
	9, 407-18, 423-4		individual's association with Maxwell, which is not salacious and has been
			widely reported in the media already. Avenatti, 2020 WL 70952, at *6:
	272-5, 320, 407-		D i Russo, 121 F.3d at 826: Lytle, 810 F. Supp. 2d at 621. Further, this individual
J. DOE 038	21, 947-1	Alleged Epstein
		Affiliate	actually requested excerpts of materials mentioning them, which the parties sent
	656-2	Media	identifying interests that outweigh the presumption of access with specificity.

Pseudonym	Relevant Characterization Docket Entries		Additional Comments/Argument
	172, 173-5, 407-		DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this
J. DOE 040	6' 407-8, 407-9•	Alleged Epstein	individual's association with Epstein has been reported in the media already, and
	450-1	Affiliate	in fact certain of the sealed documents at issue are news articles. Avenatti, 2020
	249-13, 321-1,		identifying interests that outweigh the presumption of access with specificity.
J. DOE 041	321-5, 321-6,	Alleged V mint	DiRussa, 121 F.3d at 826; Lvtle, 810 F. Supp. 2d at 621. Second, the sealed
	423-4		material as to this individual is not salacious and consists primarily of Rule 26
	249-13, 280-1,		identifying interests that outweigh the presumption of access with specificity.
	321-1, 321-5,	Alleged Epstein	DiRussa, 121 F.3d at 826; Lvtle, 810 F. Supp. 2d at 621. Second, the sealed
.1. DOE 042	321-6, 363-7	Affiliate	material as to this individual is not salacious and consists primarily of Rule 26
	423-4		disclosures.
J. DOE 043	7m. 701-1

Rel evant Pseudonym
Docket Entri es
Characterization Defendant:		Additional Comments/Argument
Defendant: Alleged Epstein Affiliate this case.	No confirmation receipt of Notice received.	The Doe was an
J. DOE 044
DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Plaintiff Alleged 249-13 280-1 Victim 321-1, 321-5, 321-6, 363-7, Defendant: 369-10, 4234 Alleged Epstein Affiliate Plaintiff: Alleged Victim 247-1, 249-13, 280-1, 321-1, J. DOE 045 Defendant: 321-5, 423-4 Alleged Epstein	R. 26 disclosure or search terms.	Second, this
at Affiliate	6:19-25; disclosure or search term.	see

Pseudonym	Relevant ( Docket Entries	hill :RIO intion	Additional Comments/Argument
J. DOE 046	258-3	Alleged Victim
			DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this
J. DOE 047	232-9, 235-8	Law Enforcement	released by the Second Circuit, and the individual appears to be a member of
	249-13, 280-1,	Plaintiff: Alleged	DiRussa, 121 F.3d at 826; Lytle, 810 F. Stipp. 2d at 621. Second, this
	321-1, 321-5,	Victim	individual's allegations against Epstein and others have been previously
J. DOE 048	321-6, 339, 423-		reported on by the press, and this individual testified publicly at a hearing before
	4	Defendant:	Judge Berman after Epstein's death. Avenatti, 2020 WL 70952, at *6; 11/18/22
		Alleged Witness	Hearing Tr. at 6:19-25.

	Relevant
Docket Entries	( hal :met iiati011 I I Additional Comments/Argument Plaintiff: Alleged Perpetrator, statements on this topic. Alleged Epstein Affiliate
J. DOE 049	p,..,;,,
	he is an alleged "perpetrator." Specifically, Plaintiff publicly stated the Defendant: Alleged Epstein following: Affiliate
J. DOE 050 J. DOE 051	Alleged Victim Affiliate 249-13, 280-1, Employee of 321-1, 321-5, Epstein 321-6, 423-4 disclosures and lists of search terms.

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
			Defendant: The parties were unable to locate an address for this individual and therefore no notice was provided. Dkt. 1116, ¶ 7. All references are either R. 26 disclosures or search terms.
J. DOE 052	150-1, 173-6, 340-3, 369-1	Plaintiff: Alleged Victim; Alleged Witness Defendant: Alleged Witness	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, the sealed material as to this individual is not salacious.
			Defendant: No confirmation of receipt of the Notice was received. Defendant knows of no basis for considering this individual a "victim".
J. DOE 057	235-13, 249-13, 280-1, 321-1, 321-5, 321-6, 338, 338-6, 423-4	Plaintiff: Alleged Victim Defendant: Alleged Victim Affiliate	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621.
			Defendant: No confirmation of receipt of the Notice was received. Defendant knows of no basis for considering this individual a "victim".
J. DOE 058	947-1	Alleged Witness Affiliate; Alleged Perpetrator	Plaintiff: Plaintiff takes no position on Docket Entry 947-1.
			Defendant: This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621.

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 059	235-10, 380, 423-1, 510-4	Alleged Perpetrator	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, this individual is alleged to have engaged in serious wrongdoing, and it is generally the privacy interests of "innocent third parties" that "weigh heavily in a court's balancing equation." <i>Amodeo</i>, 71 F.3d at 1050. Third, this individual or their representatives will have "a fair opportunity" to respond to any unsealed accusations, putting countervailing privacy interests "at the lowest." <i>Huntley</i>, 943 F. Supp. 2d at 387. Finally, this individual's name was unsealed in materials released by the Second Circuit.</p> <p>Defendant: This individual is dead and therefore will not have "a fair opportunity" to respond to any unsealed accusations which apparently was never adjudicated publicly. Dkt. 1116 at ¶ 8.</p>
J. DOE 061	249-13, 280-1, 321-1, 321-5, 321-6, 423-4	Unknown	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures.</p> <p>Defendant: The parties were unable to locate an address for this individual and therefore no notice was provided. Dkt. 1116, ¶ 7. All of the references are either in R. 26 disclosures or search terms.</p>
J. DOE 062	258-3	Alleged Victim	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, the sealed material as to this individual is not salacious.</p>

Relevant Psendons ni
Docket Entries Characterization	Additional Comments/Argument
144-4, 144-6.	identifying interests that outweigh the presumption of access with specificity.
150-1, 173-6,	DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this
235-13, 249-13,	individual's allegations against Epstein and others has been previously reported
J. DOE 063 315, 339, 340-3, Alleged Victim	on by the press, this individual has given multiple interviews to the media, and
340-4, 368, 369-	this individual testified publicly at Maxwell's criminal trial under their real
1, 423-4, 845.	name. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25:
	Defendant: Plaintiff's counsel represents this individual and so should be in a position to give her position on unsealing directly.
280-1, 315, 316- Plaintiff: Alleged	DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this
7, 321-1, 339,	Victim individual's allegations against Epstein and others has been previously reported
J. DOE 064 340-4, 368, 369-	on by the press, and this individual has given multiple interviews to the media.
3, 845, 856	Defendant: Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25: Alleged Witness
	Defendant: Plaintiff's counsel represents this individual and so should be in a position to give her position on unsealing directly.

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 065	172, 173-5, 235-13 [REDACTED] 249-13, 280-1, 321-1, 321-5, 321-6, 407-6, 423-4, 493-1	Alleged Epstein Affiliate; Alleged Witness	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. 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 their relationship with Epstein. <i>Avenatti</i> , 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. Defendant: Served
J. DOE 066	235-4, 235-13, 280-1, 316-7, 321-1, 340-4, 369-3, 381-1	Alleged Victim Affiliate; Alleged Witness	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621.
J. DOE 067	203, 211, 235-4, 235-13, 249-13, 249-14, 257, 258, 258-3, 258-4, 258-9, 261, 267, 268, 268-2, 280-1, 307-8, 315, 316, 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,	Plaintiff: Alleged Victim Affiliate; Alleged Witness Defendant: Alleged Victim Affiliate; Alleged Perpetrator; Alleged Witness	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, portions of this individual's deposition were released by the Second Circuit, meaning their name and association with this case is already public. <i>Avenatti</i> , 2020 WL 70952, at *6; 7/1/21 Hearing Tr. at 6-7. Defendant: During the criminal trial, one of the named victims testified that Plaintiff and this individual, who were then both over the age of 18, recruited her at the age of 14 to provide massages to Epstein. This Doe's first and last name were provided in open court in connection with these allegations. <i>See</i> Trial Tr. 1517, 1743 ( <i>U.S. v. Maxwell</i> , 20-cr-330).

Pseudonym	Relevant
	Docket Entries	Characterization	Additional Comments/Argument
J. DOE 068	; If,, I
			DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this
		Affiliate	Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.
	172, 173-6, 203,		raise any objection to unsealing, and thus did not meet their burden of
	211, 224, 229- 6,	Employee of	identifying interests that outweigh the presumption of access with specificity.
J. DOE 069	2494, 249-13,	Epstein;	DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this
	369-1, 4234,	Alleged Witness	individual's association with Epstein has been widely reported in the media
	435, 607-3		already. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.
	228, 235-13,		Plaintiff: This material should be unsealed in full. First, this individual did not
	280-1, 307-8,		raise any objection to unsealing, and thus did not meet their burden of
J. DOE 070	321-1, 339, 363,	Law Enforcement	identifying interests that outweigh the presumption of access with specificity.
	364, 406, 435		DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this individual

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 071	249-13, 321-5, 321-6, 423-4	Employee of Epstein; Alleged Witness	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures. Defendant: All references are either R. 26 disclosures or search terms.
J. DOE 072	249-13, 280-1, 321-1, 321-5, 321-6, 423-4	Employee of Epstein; Alleged Witness	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures. Defendant: All references are either R. 26 disclosures or search terms.
J. DOE 075	232-7, 232-9, 235-4, 235-8, 235-10, 235-13, 307-8, 363-7, 423-1	Alleged Victim Affiliate	Plaintiff: This material should be unsealed in full. This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Defendant: No confirmation of receipt of Notice was received.
J. DOE 076	450-1	Alleged Victim Affiliate	Plaintiff: This material should be unsealed in full. This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. This individual's name also appears in a publicly available police report. Defendant: The only reference is a deposition question in answer to which the deponent asserted a Fifth Amendment protection (as with all questions in the deposition).

Pseudonym	Relevant Characterization Docket Entries		Additional Comments/Argnment
	173-5, 173-6,		identifying interests that outweigh the presumption of access with specificity.
	340-5, 354, 355-		DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this
J. DOE 077	2, 363-7, 369-1,	Alleged Epstein	individual's association with Epstein has been widely reported in the media
	378, 408-1, 423-	Affiliate	already, and the Second Circuit unsealed this individual's name and information
	I, 435, 510-4		about their relationship with Epstein. Avenatti, 2020 WL 70952, at '6; 11/18/22
			Plaintiff: This material should be unsealed in full. First, this individual did not
J. DOE 078	ri i i	Affiliate;	DiRttssa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, the Second
		Alleged Witness	Circuit unsealed this individual's name and information about their relationship
	249-13, 280-1,		any objection to unsealing, and thus did not met their burden of identifying
	321-1, 321-5,	Alleged Epstein	interests that outweigh the presumption of access with specificity. DiRussa, 121
J. DOE 079	321-6, 3404,	Affiliate	F.3d at 826; Lytle, 810 F. Supp. 2d at 621.
J. DOE 080	249-13. 1' '" I	Alleged Witness	DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, the sealed

l'.i inliim in Relevant
	Characterization	Additional Comments/Argnment
655, 656-7, 656- 8. 701-1, 714	Defendant:	DiRttssa, 121 F.3d at 826; Lvtle, 810 F. Supp. 2d at 621. Further, this individual J. DOE 081
249-13, 280-1.	Plaintiff:	DiRussa, 121 F.3d at 826; Lvtle, 810 F. Supp. 2d at 621. Further, this individual
280-2, 321-1,	Employee of	actually requested excerpts of materials mentioning them, which the parties sent
321-5, 321-6,	Epstein; Alleged	them, and still raised no objection to unsealing after receiving those excerpts.
338-9, 398-5,	Perpetrator;	Second, this individual's name and association with Epstein and Maxwell has
J. DOE 082 423-4, 450-1,	Alleged Witness	been widely publicized by the media, this individual has been named as a
450-5, 655, 656-		defendant in public lawsuits relating to Epstein, and the Second Circuit unsealed
4, 656-8, 700,	Defendant:	substantial material relating to this individual. Ayentati, 2020 WL 70952, at *6.
701-1, 928, 947-	Employee of	11/18/22 Hearing Tr. at 6:19-25. Third, this individual is alleged to have
1, 957	Epstein;

it Maxwell, 15-cv-7433-LAP¶

Original Parties' Joint Chart of Non-Objecting Does (February 7, 2023)¶

Pseudonym	Relevant
	Docket Entries	Characterization	Additional Comments/Argument
J. DOE 085	340- 1	Unknown

Pseudonym	Relevant Entries
		Characterization	Additional Comments/Argument
			DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621.	Second, this
J. DOE 088	340- I	Unknown

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 089	235-13 [REDACTED] 249-13, 280-1, 321-1, 321-5, 321-6, 340-4, 369-10, 423-4	Employee of Epstein	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Further, this individual actually requested excerpts of materials mentioning them, which the parties sent them, and still raised no objection to unsealing after receiving those excerpts. Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures and lists of search terms. Finally, this individual's name and association with Epstein has been publicized by the media. <i>Avenatti</i> , 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.
	173-6, 340-3, 369-1	Alleged Epstein Affiliate	Plaintiff: This material should be unsealed in full. This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621.
			Defendant: Served
	J. DOE 091	249-13, 280-1, 321-1, 321-5, 321-6, 423-4	Alleged Victim	Plaintiff: This material should be unsealed in full. This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621.
				Defendant: Served

	Relevant
P.i inborn m	Docket Entries	Characterization	Additional Comments/Argument
J. DOE 092 J. DOE	None Identified	Alleged Epstein Affiliate Defendant: Served
	701-1	Alleged Victim Affiliate	to this individual, but did not receive a delivery confirmation.

²The Court previously unsealed materials relating to an individual identified as Doe 93 who had objected to unsealing, but Plaintiff had misidentified that individual's pseudonym number based on a prior, outdated version of the non-party list. Apr. 19, 2022, Hr'g Tr. at 7:1-10. The parties kept materials relating to that individual sealed, as ordered by the Court.¶

Pseudonym	Relevant Characterization Docket Entries		Additional Comments/Argument
J. DOE 095	338-9, 398-5	Alleged Epstein
J. DOE 096	576	Alleged Victim

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 098	340-4	Unknown	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Plaintiff was unable to locate any address for this individual.</p> <p>Defendant: Plaintiff located no address for this person. Only reference is a deposition question to which the deponent denied knowledge of the Doe.</p>
J. DOE 099	passim	Employee of Epstein; Alleged Perpetrator	<p>Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party notice to this individual's counsel and received delivery confirmation. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, this individual's name and association with Epstein and Maxwell has been widely publicized by the media, this individual has been named as a defendant in public lawsuits relating to Epstein, and the Second Circuit unsealed substantial material relating to this individual. <i>Avenatti</i>, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. Third, this individual is alleged to have engaged in serious wrongdoing, and it is generally the privacy interests of "innocent third parties" that "weigh heavily in a court's balancing equation." Amodeo, 71 F.3d at 1050. Finally, this individual will have "a fair opportunity" to respond to any unsealed accusations, putting countervailing privacy interests "at the lowest." <i>Huntley</i>, 943 F. Supp. 2d at 387.</p>
J. DOE 100	340-4	Unknown	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621.</p> <p>Defendant: Plaintiff located no address for this person. Only reference is a deposition question to which the deponent denied knowledge of the Doe.</p>

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 101	235-13, 280-1, 321-1, 423-1, 510-4	Alleged Victim Affiliate	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Further, this individual actually requested excerpts of materials mentioning them, which the parties sent them, and still raised no objection to unsealing after receiving those excerpts. Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures and lists of search terms. Plaintiff sent a non-party notice to this individual. Although Plaintiff did not receive delivery confirmation, this individual received the notice because they requested excerpts and did not lodge and objection to unsealing.
J. DOE 102	280-2, 338-9, 398-5	Alleged Epstein Affiliate	Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party notice to this individual's counsel and received delivery confirmation. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, this individual's name and association with Epstein has already been publicized by the media.
J. DOE 103	235-13, 363-7	Alleged Epstein Affiliate	Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party notice to this individual's counsel and received delivery confirmation. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. 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 their relationship with Epstein. <i>Avenatti</i> , 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.
J. DOE 104	247-1	Unknown	Plaintiff: This material should be unsealed in full. This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621.

Pseudonym	Relevant
	Docket Entries	t haracteriiation	Additional Comments/Argument
	249-13, 280-1,		Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party
	321-1, 321-5.	Alleged Epstein	notice to this individual and received delivery confumation. This individual did
J. DOE 106	321-C 423-4.	Affiliate	not raise any objection to unsealing, and thus did not meet their burden of
	435		identifying interests that outweigh the presumption of access with specificity.
J. DOE 108	701- I	Alleged Witness	burden of identifying interests that outweigh the presumption of access with
	185-3, 363, 450- 1, 450-5, 568-3	Alleged Epstein burden of identifying interests that outweigh the presumption of access with J. DOE 109 Affiliate	specificity. DiRussa, 121 F.3d at 826; Lvtle, 810 F. Supp. 2d at 621. Second.

Relevant PseutionN ni
Docket Entries Characterization 173-6, 249-13,		Additional Comments/Argument
339, 340_3, 340.
DiRtasa, 280-1, 321-1, 321-5, 321-6, Alleged Epstein J. DOE 110 Affiliate 4, 363-7, 369-1,	121 F.3d at 826;	Lyle, 810 F. Supp. 2d at 621. Further, this individual
publicized by the media. 423-4		Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr.
at 6:19-25. unsealing. 249-13, 280-1	Plaintiff sent a non-party notice to this individual.	Although
i Doi I I I
interests that outweigh the presumption of access with specificity. Employee of 321-1, 321-5.		DiRtissa, 121
F.3d at 826; Epstein 321-6, 423-4 235-13, 249-13,	Lytle,	810 F. Supp. 2d at 621.
DiRussa, Alleged Epstein 280-1, 321-1. J. DOE 112 Affiliate 423-4	121 F.3d at 826;	Lytle, 810 F. Supp. 2d at 621. Second, this
media.	Avenatti,	2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

Pseudonym	Relevant
		Characterization	Additional Comments/Argument
	249-13, 280-1,		DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this individual
	321-1, 321-5.	Alleged Epstein	is alleged to have engaged in serious wrongdoing, and it is generally the privacy
J. DOE 113	321-6, 423-4	Affiliate;	interests of "innocent third parties" that "weigh heavily in a court's balancing
	435	Alleged Witness	equation." Amodeo, 71 F.3d at 1050. Plaintiff sent a non-party notice to this
J. DOE 114	173-6, 369-1	Alleged Epstein
		Affiliate	F.3d at 826; Lytle, 810 F. Supp. 2d at 621.
.1 Doi IV		Allege jr psten i

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 116	398-4, 338, 338-8, 468, 469-1, 660-1	Employee of Epstein	Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party notice to this individual and received delivery confirmation. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Further, this individual actually requested excerpts of materials mentioning them, which the parties sent them, and still raised no objection to unsealing after receiving those excerpts. Finally, the sealed material as to this individual is not salacious.
J. DOE 117	450-1, 471-1	Law Enforcement Officer	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, this individual is a former law enforcement official and, 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. Plaintiff was unable to locate an address for this individual.
J. DOE 118	249-13, 280-1, 321-1, 321-5, 321-6, 423-4	Alleged Epstein Affiliate	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures. Plaintiff sent a non-party notice to this individual, but did not receive a delivery confirmation. Defendant: Plaintiff located no address for this person.
J. DOE 119	249-13, 280-1, 321-1, 321-5, 321-6, 340-4, 423-4	Alleged Epstein Affiliate	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
			disclosures. Plaintiff sent a non-party notice to this individual, but did not receive a delivery confirmation.
J. DOE 120	576, 655, 656-4, 656-5, 656-6, 656-7, 700, 701-1, 947-1	<p>Plaintiff: Employee of Epstein; Alleged Perpetrator; Alleged Witness</p> <p>Defendant: Employee of Epstein; Alleged Witness</p>	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, this individual's name and association with Epstein and Maxwell has been widely publicized by the media and this individual has been named as a defendant in public lawsuits relating to Epstein. <i>Avenatti</i>, 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"). Third, this individual is alleged to have engaged in serious wrongdoing, and it is generally the privacy interests of "innocent third parties" that "weigh heavily in a court's balancing equation." <i>Amodeo</i>, 71 F.3d at 1050. Finally, this individual will have "a fair opportunity" to respond to any unsealed accusations, putting countervailing privacy interests "at the lowest." <i>Huntley</i>, 943 F. Supp. 2d at 387. Plaintiff sent a non-party notice to this individual, but did not receive a delivery confirmation.</p>
J. DOE 121	381-1	Law Enforcement	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. 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 discussing this individual is already publicly available on the docket with this individual's name unredacted. <i>See</i> D.E. 1199-8. Plaintiff sent a non-party notice to this individual, but did not receive a delivery confirmation.</p>

Relevant Psendon% m
Docket Entries 150-1, 173-6, 203, 211, 224,	Characterization	Additional Comments/Argument
235-4, 280-1, 320, 321-1, 321- 6, 340-3, 340-4, J. DOE 122 369, 369-1, 407, 407-9, 655, 656- 5, 656-6, 656-9, 700, 701-1, 701-	DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Employee of Epstein; Alleged . Perpetrator, Alleged Witness	Second. this
260-2, 270-6. J. DOE 123 272-9	Huntley, 943 F. Supp. 2d at 387. Alleged Victim Affiliate	Plaintiff sent a non-party notice to this individual, but did not receive a delivery confirmation. individual, but did not receive a delivery confirmation.
J. DOE 124 701-1	Alleged Witness	F.3d at 826; Lytle, 810 F. Supp. 2d at 621.
	Defendant:	Plaintiff located no address for this person. The witness's allegations against this individual are salacious.

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 125	235-13, 249-13, 280-1, 321-1, 321-5, 321-6, 423-4	Alleged Epstein Affiliate	Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party notice to this individual and received delivery confirmation. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this individual's name and association with Epstein has been publicized by the media. <i>Avenatti</i> , 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.
J. DOE 126	249-13, 280-1, 321-1, 321-5, 321-6, 423-4	Alleged Epstein Affiliate	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this individual's name and association with Epstein has been publicized by the media. <i>Avenatti</i> , 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. Plaintiff sent a non-party notice to this individual, but did not receive a delivery confirmation.
J. DOE 127	235-13, 280-1, 321-1	Alleged Victim Affiliate; Witness	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, this individual's name appears in a publicly available police report. Plaintiff sent a non-party notice to this individual, but did not receive a delivery confirmation.
J. DOE 128	249-13, 280-1, 321-1, 321-5, 321-6, 423-4	Employee of Epstein	Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party notice to this individual and received delivery confirmation. This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621.
J. DOE 129	249-13, 280-1, 321-1, 321-5, 321-6, 423-4	Employee of Epstein	Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party notice to this individual and received delivery confirmation. This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621.

Pseudonym	Relevant Characterization Docket Entries		Additional Comments/Argument
J. DOE 130	450-1, 471-1	Law Enforcement	burden of identifying interests that outweigh the presumption of access with
	203, 211, 232,		Plaintiff: This material should be unsealed in full. First, this individual did not
	235, 235-7, 235-		raise any objection to unsealing, and thus did not meet their burden of
	13, 2494, 258-		identifying interests that outweigh the presumption of access with specificity.
J. DOE 131	10, 2804' 320,
		Alleged Victim	DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, portions of
	321-1, 368, 369,	Affiliate	this individual's deposition were released by the Second Circuit, meaning their
	369-8, 392, 393,		name and association with this case is already public. Avenatti, 2020 WL 70952.
	393-1		at *6; 7/1/21 Hearing Tr. at 6-7. Plaintiff sent a non-party notice to this
	173-5, 173-6,		DiRitssa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this individual
	235-13, 280-1,	Plaintiff Alleged
		Epstein Affiliate;	is alleged to have engaged in serious wrongdoing, and it is generally the privacy
	321-1, 321-5,	Alleged	interests of "innocent third parties," not those accused of serious misconduct.
J. DOE 132	321-6, 340-5,	Perpetrator	that "weigh heavily in a court's balancing equation." United States v. Amodeo.
	363-7, 369-1,		71 F.3d 1044, 1050 (2d Cir. 1995). Finally, allegations about this individual
		Alleged Epstein	have been widely reported in the media, and the Second Circuit unsealed
	3, 514-3, 701-1	Affiliate:	allegations about this individual in this case. Avenatti, 2020 WL 70952, at *6:

Pseudonym	Relevant
	Docket Entries	Characterization	Additional Comments/Argument
			DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this
	173-6, 228, 249-		individual's name and association with Epstein and Maxwell has been
	13, 280-1, 321-	Alleged Epstein	publicized by the media. Avenatti, 2020 WL 70952, at *6: 11/18/22 Hearing Ti.
J. DOE 134	1, 321-5, 321-6,	Affiliate;	at 6:19-25. Third, this individual is alleged to have engaged in serious
	369-1, 423-4	Alleged Witness	wrongdoing, and it is generally the privacy interests of "innocent third parties"
	173-6, 235-13,		any objection to unsealing, and thus did not met their burden of identifying
J. DOE 135	321-5, 321-6,	Alleged Victim	interests that outweigh the presumption of access with specificity. DiRussa, 121
	340-3, 369-1		F.3d at 826; Lytle, 810 F. Supp. 2d at 621.

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 136	184, 185-3, 249-13, 280-1, 321-1, 321-5, 321-6, 406, 407, 408, 408-1, 423-4, 435	<p>Plaintiff: Employee of Epstein; Alleged Perpetrator; Alleged Witness</p> <p>Defendant: Employee of Epstein Alleged Witness</p>	<p>Plaintiff: This individual is the same individual as Doe 157. This material should be unsealed in full. Plaintiff sent a non-party notice to this individual and received delivery confirmation. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, this individual's name and association with Epstein and Maxwell 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"). Third, this individual is alleged to have engaged in serious wrongdoing, and it is generally the privacy interests of "innocent third parties" that "weigh heavily in a court's balancing equation." <i>Amodeo</i>, 71 F.3d at 1050. Finally, this individual will have "a fair opportunity" to respond to any unsealed accusations, putting countervailing privacy interests "at the lowest." <i>Huntley</i>, 943 F. Supp. 2d at 387.</p>
J. DOE 137	363-7	Alleged Epstein Affiliate	<p>Plaintiff: This material should be unsealed in full. This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. The information relating to his individual is also not salacious.</p> <p>Defendant: Plaintiff located no address for this person. The only reference is a deposition question to which the Party denied knowledge of.</p>
J. DOE 138	381-1	Alleged Victim Affiliate	<p>Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party notice to this individual and received delivery confirmation. This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Further, this individual's name appears only in a public police report and was already released by this Court. <i>See</i> D.E. 1199-8.</p>

Pseudonym	Relevant Characterization Docket Entries		Additional Comments/Argument
			notice to this individual and received delivery confirmation. First, this
	249-13, 280-1,		individual did not raise any objection to unsealing, and thus did not meet then
J. DOE 139	321-1, 321-5.	Employee of	burden of identifying interests that outweigh the presumption of access with
	321-6, 423-4	Epstein	specificity. DiRussa, 121 F.3d at 826: Lytle, 810 F. Supp. 2d at 621. Second.
	249-13, 280- I .		identifying interests that outweigh the presumption of access with specificity.
J. DOE 140	280-2, 321-1.	Employee of	DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, the Second
	423-4	Epstein	Circuit unsealed this individual's name and relationship with Epstein. Avenatti,
	249-13, 363-7.	Employee	identifying interests that outweigh the presumption of access with specificity.
i DOI I II	423-4	of DiRussa, 121 F.3d at 826; Lytle, 810 F. Stipp. 2d at 621. Second, the Second Epstein	Circuit previously unsealed this individual's name. Avenatti, 2020 WL 70952,
	228, 249-13,		Plaintiff: This material should be unsealed in full. First, this individual did not
	321-1, 321-5, identifying interests that outweigh the presumption of access with specificity. J. DOE 142 321-6, 3404,	Alleged Epstein Affiliate	DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, the sealed
	4234		material as to this individual is not salacious. Plaintiff sent a non-party notice

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 143	passim	Alleged Perpetrator; Alleged Epstein Affiliate; Alleged Witness	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, this individual's association with Epstein and Maxwell has been widely reported in the media already, and their name came up at Maxwell's public criminal trial. <i>Avenatti</i> , 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. This individual was also named as a defendant in public, federal lawsuit involving the same conduct underlying this action. Third, this individual is alleged to have engaged in serious wrongdoing, and it is generally the privacy interests of "innocent third parties" that "weigh heavily in a court's balancing equation." <i>Amodeo</i> , 71 F.3d at 1050. Finally, this individual will have "a fair opportunity" to respond to any unsealed accusations, putting countervailing privacy interests "at the lowest." <i>Huntley</i> , 943 F. Supp. 2d at 387.
J. DOE 145	249-13, 321-1, 321-5, 321-6, 368, 369, 369-12, 423-4, 513, 514, 514-5, 568-5, 607-3	Employee of Epstein	Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party notice to this individual and received delivery confirmation. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Portions of this individual's 2009 deposition in a matter against Epstein were also unsealed by the Second Circuit.
J. DOE 146	701-1	Plaintiff: Alleged Victim Affiliate Defendant: Alleged Witness Affiliate	Plaintiff: This material should be unsealed in full. This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Defendant: Plaintiff located no address for this person.

Pseudonym	Relevant	Characterization Docket Entries	Additional Comments/Argument
			requested excerpts. First, this individual did not raise any objection to
	235-4,	Affiliate;	outweigh the presumption of access with specificity. DiRussa, 121 F.3d at 826: 11, 228, Lytle, 810 F. Supp. 2d at 621. Second, this individual's association with Epstein
	235-13, 249-13, 363-7, 4234,	Alleged Witness	and Maxwell has been widely reported in the media already, and their name was J. DOE 148 unsealed by the Second Circuit previously. Avenatti, 2020 WL 70952, at *6.
	435, 450-1, 701-	Defendant:	11/18/22 Hearing Tr. at 6:19-25. Third, this individual is alleged to have
	1	Alleged Epstein	engaged in serious wrongdoing, and it is generally the privacy interests of
		Affiliate;	"innocent third parties" that "weigh heavily in a court's balancing equation."
		Alleged Witness	Amodeo, 71 F.3d at 1050. Finally, this individual will have "a fair opportunity"
J. DOE 149	173-5	Law Enforcement	interests that outweigh the presumption of access with specificity. DiRussa, 121
J. DOE 150	229-1	Alleged Witness	F.3d at 826; Lytle, 810 F. Supp. 2d at 621. The deposition of this individual's

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 152	235-13, 423-1, 510-4	Alleged Victim Affiliate	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, this individual has given statements to the media in connection with this matter. <i>Avenatti</i>, 2020 WL 70952, at *6; 7/1/21 Hearing Tr. at 6-7.</p> <p>Defendant: Plaintiff located no address for this person.</p>
J. DOE 153	203, 211, 235-4, 235-13, 249-4, 280-1, 321-1, 338, 423-1, 423-4, 510-4	Alleged Victim Affiliate; Alleged Witness	<p>Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, this individual has given statements and interviews to the media in connection with this matter, and portions of this individual's deposition were released by the Second Circuit. <i>Avenatti</i>, 2020 WL 70952, at *6; 7/1/21 Hearing Tr. at 6-7; [REDACTED] Plaintiff sent a non-party notice to this individual, but did not receive a delivery confirmation.</p>
J. DOE 154	173-6, 249-13, 258-4, 280-1, 321-1, 321-5, 321-6, 340-3, 340-4, 369-1, 423-4, 450-1, 482-4	Alleged Underage Victim; Alleged Witness	<p>Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party notice to this individual and received delivery confirmation. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Second, this individual's allegations against Epstein and others have been previously reported on by the press, and this individual has given interviews to the media. <i>Avenatti</i>, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25; [REDACTED]</p>

Pseudonym	Relevant
	Docket Entries	Characterization	Additional Comments/Argument
	5, 606, 607, 607-
			DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621.	Second, this

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 157	249-13, 321-5, 321-6, 338, 338-9, 398-5, 407, 407-9, 423-4, 450-1, 450-5, 660-1	Plaintiff: Employee of Epstein; Alleged Perpetrator; Alleged Witness Defendant: Employee of Epstein Alleged Witness	Plaintiff: This individual is the same individual as Doe 136. This material should be unsealed in full. Plaintiff sent a non-party notice to this individual and received delivery confirmation. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this individual's name and association with Epstein and Maxwell has been widely publicized by the media and this individual has been named as a defendant in public lawsuits relating to Epstein. <i>Avenatti</i> , 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"). Third, this individual is alleged to have engaged in serious wrongdoing, and it is generally the privacy interests of "innocent third parties" that "weigh heavily in a court's balancing equation." <i>Amodeo</i> , 71 F.3d at 1050. Finally, this individual will have "a fair opportunity" to respond to any unsealed accusations, putting countervailing privacy interests "at the lowest." <i>Huntley</i> , 943 F. Supp. 2d at 387.
J. DOE 158	173-6, 369-1, 235-13, 320, 450-1	Alleged Epstein Affiliate	Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party notice to this individual and received delivery confirmation. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, this individual's relationship with Epstein has been widely publicized by the media. <i>Avenatti</i> , 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.
J. DOE 159, J. DOE 160	701-1	Alleged Witness Affiliate	Plaintiff: This material should be unsealed in full. This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Defendant: Plaintiff located no address for these persons, who are believed to live abroad.

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 161	381-1	Alleged Victim Affiliate	<p>Plaintiff: This material should be unsealed in full. This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. This individual's name also appears in a publicly available police report. Finally, the only document that substantively discusses this individual is already publicly available on the docket with this individual's name unredacted. <i>See</i> D.E. 1199-10.</p> <p>Defendant: Plaintiff located no address for this person. Only reference appears to relate to juvenile criminal conduct by this individual in regards to Plaintiff, unclear why not redacted by the law enforcement agency.</p>
J. DOE 162	143, 144-6, 150-1, 172, 173, 173-5, 173-6, 189, 203, 204, 204-1, 211, 212, 212-1, 224, 249-4, 249-13, 257, 258, 258-2, 261, 272-7, 280-1, 315, 316, 316-1, 316-6, 316-8, 321-1, 321-5, 321-6, 338, 338-1, 338-7, 339, 340, 340-3, 340-4, 340-5, 340-6, 363-7, 368, 369, 369-1, 369-2, 369-5, 378, 388, 389,	Alleged Victim; Alleged Witness	<p>Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party notice to this individual's counsel and received delivery confirmation. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i>, 121 F.3d at 826; <i>Lytle</i>, 810 F. Supp. 2d at 621. Further, this individual actually requested excerpts of materials mentioning them, which the parties sent them, and still raised no objection to unsealing after receiving those excerpts. Finally, this individual's allegations against Epstein and others has been previously reported on by the press, this individual gave an interview to the Daily Mail in 2021, and the Second Circuit unsealed substantial information relating to this individual. <i>Avenatti</i>, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25; [REDACTED]</p>

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
	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
J. DOE 163	405-1	Media	Plaintiff: This individual is a journalist, and thus materials relating to this individual should be unsealed in full.
J. DOE 164	316-7, 340-4, 369-3	Alleged Underaged Victim; Alleged Witness	Plaintiff: This material should be unsealed in full. This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Plaintiff sent a non-party notice to this individual, but did not receive a delivery confirmation.
J. DOE 165	340-4	Unknown	Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party notice to this individual and received delivery confirmation. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, the sealed material as to this individual is not salacious. Defendant: Only reference is a deposition question after which the deponent denied knowledge of the individual.

Pseudonym	Relevant
	Docket Entries	Characterization	Additional Comments/Argument
	173-5, 173-6,		notice to this individual's production company and received delivery
	363-7, 369-1,	presumption Alleged Epstein	thus did not meet their burden of identifying interests that outweigh the
	369-10, 407-6,	Affiliate	Supp. 2d at 621. Second, this individual's association with Epstein and Maxwell
	435, 632-1		has been widely reported in the media already, and their name came up during
			Maxwell's public criminal trial. Avenatti, 2020 WL 70952, at '1'6; 11/18/22
	173-6, 249-13.		is alleged to have engaged in serious wrongdoing, and it is generally the privacy
	280-1, 321-1,	Alleged Epstein	interests of "innocent third parties" that "weigh heavily in a court's balancing
J. DOE 167	321-5, 321-6,	Affiliate:	equation." Amodeo, 71 F.3d at 1050. Finally, this individual will have "a fah
	363-7, 369-1.	Alleged Witness	opportunity" to respond to any unsealed accusations, putting countervailing
	423-4		privacy interests "at the lowest." Huntley, 943 F. Supp. 2d at 387. Plaintiff was
			Defendant: Apart from R. 26 disclosures and search terms, a pail) deponeni
	235-13, 249-13,		raise any objection to unsealing, and thus did not meet their burden of
	280-1, 321-1,	Employee of	identifying interests that outweigh the presumption of access with specificity.
J. DOE 168	321-5, 321-6,	Epstein;	DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Plaintiff was unable
	423-4	Alleged Witness	to locate an address for this individual.

Pseudonym	Relevant
	Docket Entries	Characterization	Additional Comments/Argument
J. DOE 169	363-7, 435	Alleged Epstein
J. DOL I -2	173-6, 369-1	Alleged Epstein
			DiRussa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621.	Second, the only

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 174	173-5, 340-5, 363-7, 407-6, 435, 656-2, 657, 701-1, 947-1	Alleged Epstein Affiliate	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, this individual's association with Epstein and Maxwell has been widely reported in the media already, and their name came up during Maxwell's public criminal trial. <i>Avenatti</i> , 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. Plaintiff sent a non-party notice to this individual, but did not receive a delivery confirmation.
J. DOE 175	173-6, 340-3, 340-4, 369-1, 369-10	Alleged Epstein Affiliate	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, this individual's association with Epstein and Maxwell has been widely reported in the media already, and their name came up during Maxwell's public criminal trial. <i>Avenatti</i> , 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25. Plaintiff sent a non-party notice to this individual, but did not receive a delivery confirmation.
J. DOE 176	249-13, 321-5, 321-6, 423-4	Employee of Epstein	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures. Plaintiff sent a non-party notice to this individual, but did not receive a delivery confirmation. Defendant: All references are either in R. 26 disclosure or search terms.

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
J. DOE 177	235-4, 235-13, 423-1, 510-4	Alleged Victim Affiliate	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, the sealed material as to this individual is not salacious. Plaintiff was unable to locate an address for this individual.
J. DOE 178	258-3, 568-4	Alleged Underage Victim	Plaintiff: This material should be unsealed in full. Plaintiff sent a non-party notice to this individual and received delivery confirmation. This individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621.
J. DOE 179	173-8, 340-6, 400, 401-3, 450-6	Alleged Epstein Affiliate	Plaintiff: This material should be unsealed in full. First, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, this individual's name was unsealed in materials released by the Second Circuit.
J. DOE 180	173-6, 340-3, 369-1	Epstein Employee	Plaintiff: 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, this individual did not raise any objection to unsealing, and thus did not meet their burden of identifying interests that outweigh the presumption of access with specificity. <i>DiRussa</i> , 121 F.3d at 826; <i>Lytle</i> , 810 F. Supp. 2d at 621. Second, this individual testified publicly at Maxwell's criminal trial, weighing against continued sealing. <i>Avenatti</i> , 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. Plaintiff was unable to locate an address for this individual.

INeinlinn in	Relevant
	Docket Entries	Characterization	Additional Comments/Argument
	173-6, 249-13,		individual did not raise any objection to unsealing, and thus did not meet their
	280-1, 280-2,		burden of identifying interests that outweigh the presumption of access with
	321-1, 321-5,	Epstein	specificity. DiRussa, 121 F.3d at 826: Lytle, 810 F. Supp. 2d at 621. Second.
J. DOE 181	321-6, 363-7,	Employee;	this individual testified publicly at Maxwell's criminal trial, weighing against
	407-9, 423-4,	Alleged Witness	continued sealing. Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at
	435		6:19-25. Portions of this individual's deposition in this matter were also unsealed by the Second Circuit.
J DOE 182	340- I	Alleged Epstein Affiliate
			Defendant: The only reference is in a deposition question that was never answered.
J. DOE 184	435	Alleged Epstein	DiRussa, 121 F.3d at 826; Lytle, 810 F. Stipp. 2d at 621. Second, this
		individual,s association with Epstein has been reported in the media already. Affiliate	Avenatti, 2020 WL 70952, at *6; 11/18/22 Hearing Tr. at 6:19-25.

	Relevant
INeticlom nt	Docket Entries	Characterization	Additional Comments/Argument
	235-13, 249-13,		specificity. DiRussa, 121 F.3d at 826; Lvtle, 810 F. Supp. 2d at 621. Second.
J. DOE 185	321-1, 321-5,	Alleged Victim;	reported on by the press, this individual has given multiple interviews to the
	321-6, 423-1	Alleged Witness	media, and this individual has been a plaintiff in public lawsuits relating to Tr. at 6:19-25;
	235-13, 280-1,	Alleged Victim	specificity. DiRussa, 121 F.3d at 826; Lvtle, 810 F. Supp. 2d at 621. Further.
J. DOE 186	321-1	Affiliate	this individual actually requested excerpts of materials mentioning them, which
	249-13, 280-1,		notice to this individual, received delivery confirmation, and this individual
	321-1, 321-5,	Employee of	request excerpts. First, this individual did not raise any objection to unsealing.
J. DOE 187	321-6, 407-9,	Epstein;	and thus did not meet their burden of identifying interests that outweigh the
	423-4	Alleged Witness	presumption of access with specificity. DiRussa, 121 F.3d at 826; Lvtle, 810 F.

v. Maxwell, 15-cv-7433-LAP¶

Original Parties' .loin t 'hart of Non-Objecting Does (February 7, 2023)¶

Pseudonym	Relevant Docket Entries	Characterization	Additional Comments/Argument
			<p>unsealing after receiving those excerpts. Second, the sealed material as to this individual is not salacious and consists primarily of Rule 26 disclosures and lists of search terms.</p> <p>Defendant: All references are R. 26 disclosures, search terms, or one deponent's refusal to answer whether the Doe is known to them, and refusing to answer all questions.</p>