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Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 24 of 69 The movant bears the burden of proof to show factors that outweigh the ordinary presumption of judicial openness. Doe v. Cook Cty., Illinois, No. 1:20-CV-5832, 2021 WL 2258313, at *3 (N.D. Ill. June 3, 2021). And, in the context of maintaining an alleged victim’s anonymity for the types of reasons proffered by the government, “conclusory statements are of limited utility.” Rapp v. Fowler, No. 20-CV-9586 (LAK), 2021 WL 1738349, at *6 (S.D.N.Y. May 3, 2021). Even if the government’s motion was supported by any evidence, “claims of public humiliation and embarrassment” due to “significant media attention. . . are not sufficient grounds for allowing” an accuser to proceed anonymously. ” Doe v. Shakur, 164 F.R.D. 359, 361-62 (S.D.N.Y. 1996) (denying motion to proceed by pseudonym brought by woman who alleged that rapper Tupac Shakur assaulted her despite the media attention the case likely was to attract); see also Doe v. Weinstein, 484 F. Supp. 3d 90, 95 (S.D.N.Y. 2020) (denying motion to proceed by pseudonym brought by woman who alleged that movie producer Harvey Weinstein assaulted her despite that Weinstein's infamy was likely to cause significant media attention); see also People v. Harvey Weinstein, Indictment Nos. 02335/2018 and 2673/19 (N.Y. Sup. Ct.) With no analysis relating to the facts of this case, the government has cobbled together a variety of cases holding that under certain limited circumstances the identity of alleged sex assault victims may be publicly suppressed. Generally, these cases fall into a few overlapping DOJ-OGR-00005479