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Case 1:20-cr-00330-PAE Document 380 _ Filed 10/29/21 Page17 of 54 disclosure of such information will identify the Minor Victims with particularity, and thus subject them to harassment, retaliation, and embarrassment, or additional consequences.’ The sealing of exhibits containing the names of Minor Victim-1, Minor Victim-3, and Witness-1, or the last names of Minor Victim-4 and Minor Victim-6, is also appropriate. Although “the public has an ‘especially strong’ right of access to evidence introduced in trials,” United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995), it “is not absolute,” Nixon v. Warner Comme ns, Inc., 435 U.S. 589, 598 (1978); see also United States v. Graham, 257 F.3d 143, 149 (2d Cir. 2001). For example, “subject matter [that] is traditionally considered private rather than public” will weigh “heavily against access.” Amodeo, 71 F.3d at 1050. This includes certain “financial records . . . , family affairs, illnesses, embarrassing conduct with no public ramifications, and similar matters ....” Jd. at 1051. “[T]he ‘venerable’ privacy-interest exception to the presumption of access exists to avert ‘cater[ing] ‘to a morbid craving for that which is sensational and impure.’” United States v. Cohen, 366 F. Supp. 3d 612, 626-627 (S.D.N.Y. 2019) (quoting Amodeo, 71 F.3d at 1051). The Government’s sealing request is narrowly tailored to prevent public disclosure only of those exhibits which would identify by name the Minor Victims testifying in this case. Any other result would defeat the purpose of permitting the Minor Victims to testify using pseudonyms or their first names, incurring all the harms described above. See Paris, 2007 WL 1484974, at *2 (concluding that the interest in 7 For the same reasons, any courtroom sketch artists should be precluded from drawing the faces of victims. See May 6, 2019 Text Order, Raniere, 18 Cr. 204 (NGG) (E.D.N.Y.) (“Sketch artists . . may not draw exact likenesses of jurors or witnesses other than co-defendants should they testify ....”). 16 DOJ-OGR-00005410