Case 1:15-cv-07433-LAP Document 1301-1 Filed 02/07/23 Page 1 of 58 v. Maxwell, 15-cv-7433-LAP Original Parties' Joint Chart of Non-Objecting Does (February 7, 2023) Pseudon •vm J. DOE 003 J DOE 004 Relevant Docket Entries 235-13, 249-13. 280-1, 321-1. 423-4 235-13, 249-13, 280 1, 321-1, 423-4 Characterization Employee of Epstein: Alleged Witness Employee of Epstein; Alleged Witness Additional Comments/Argument 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." DiRussa v. Witter Inc., 121 F.3d 818, 826 (2d Cr. 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." Lytle v. JPMorgan Chase, 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. 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 7:1116 (unsealing documents relating to Doe who gave media interviews and was identified in the press); see 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. 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. DiRtissa, 121 F.3d at 826; Lytle, 810 F. Supp. 2d at 621. Second, this individual gave a