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Case 1:20-cr-00330-PAE Document581 Filed 01/24/22 Page4of5 January 21, 2022 Page 4 visual distortion to hide his identity,” and he has openly discussed not only his experience on the Maxwell jury, but also his past sexual abuse that gave rise to the filing of Ms. Maxwell’s motion for a new trial.’ In fact, it was Juror No. 50’s public statements to the press that Jed to Ms. Maxwell moving for a new trial. The controversy began in the public arena, and any attempts by Ms. Maxwell to now shut the media and the public out of it are baseless. Where information that a party seeks to seal has already been made public, the party cannot meet its burden of overcoming the presumption of public access. See Alcon Vision, LLC v. Lens.com, No. 18-CV-0407 (NG), 2020 WL 3791865, at *7—-8 (E.D.N.Y. July 7, 2020) (“[Party contesting unsealing| cannot defeat the already heavy presumption in favor of public access with 299 respect to materials that are ‘already in the public domain.’”). Continued sealing of documents that are already in the public domain would be “futile.” Jn re Application to Unseal 98 Cr. LIO1(ILG), 891 F. Supp. 2d 296, 300 (E.D.N.Y. 2012) (“[T]he cat is out of the bag, the genie is out of the bottle.”). The Court “simply do[es] not have the power, even were we of the mind to use it if we had, to make what has thus become public private again.” Gambale, 377 F.3d at 144. Ms. Maxwell has no basis for arguing that the entirety of the submissions regarding Juror No. 50 should be sealed, when the same information has already been widely disseminated among the public. See In re Application to Unseal 98 Cr. 1101(ILG), 891 F. Supp. 2d at 300 (“Any balancing of the interests here, however, would be academic as the information the Government and Doe seek to maintain sealed has already been publicly revealed... .”). 2 See “EXCLUSIVE: Never-before-seen video captures the moment Ghislaine Maxwell juror Scotty David claimed he 'wasn't asked’ about his sexual abuse history in jury questionnaire ...,” Daily Mail, (Jan. 7, 2022), https:/Avww.dailymail.co.uk/news/article-10380247/Never-seen-video-shows-moment-Ghislaine-Maxwell-juror- sent-conviction-chaos.html. 3 See the articles cited in note 1, supra. DOJ-OGR-00008827