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government might have `forgotten' the presumption of innocence in such a public pleading . . .") (citing Smith, 656 F.2d at 1107); United States v. Holy Land Foundation, 624 F.3d 685 (5th Cir. 2010) (Fifth Amendment rights of organization were violated when its name was listed among 246 unindicted coconspirators in
10 of access is not absolute and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States v. Steinger, 626 F. Supp. 2d 1231 (S.D. Fl. 2009): "The proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings," Dougla
e government might have 'forgotten' the presumption of innocence in such a public pleading . .") (citing Smith , 656 F.2d at 1107); United States v. Holy Land Foundation , 624 F.3d 685 (5th Cir. 2010) (Fifth Amendment rights of organization were violated when its name was listed among 246 unindicted coconspirators i
ght of access is not absolute and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States v. Steinger , 626 F. Supp. 2d 1231 (S.D. Fl. 2009): "The proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings," Doug
the government might have 'forgotten' the presumption of innocence in such a public pleading ...") (citing Smith, 656 F.2d at 1107); United States' Holy Land Foundation, 624 F.3d 685 (5th Cir. 2010) (Fifth Amendment rights of organization were violated when its name was listed among 246 unindicted coconspirators in
r Court, 464 U.S. 501 (1984)] so as to warrant scaling, and provides good cause under the common-law access balancing test to preclude disclosure. Steinger, 626 F. Supp. 2d at 1235-36 (brackets in original omitted). See also In re Petition of American Historical Assn, 62 F. Supp. 2d 1100, 1103 (S.D.N.Y.
government might have `forgotten' the presumption of innocence in such a public pleading .. .') (citing Smith, 656 F.2d at 1107); United States v. Holy Land Foundation, 624 F.3d 685 (5th Cir. 2010) (Fifth Amendment rights of organization were violated when its name was listed among 246 unindictod coconspirators 'T
10 of access is not absolute and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States v. Steinger, 626 F. Supp. 24i 1231 (S.D. Fl. 2009): "The proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings," Dougl
he government might have 'forgotten' the presumption of innocence in such a public pleading .. .') (citing Smith, 656 F.2d at 1107); United States, Holy Land Foundation, 624 F.3d 685 (5th Cir. 2010) (Fifth Amendment rights of organization were violated when its name was listed among 246 unindicted coconspirators 'T
cy seeks to protect . . unindicted individuals from the anxiety, embarrassment, and public castigation that may result from disclosure.") (cited in Steinger). 5 08-80736-CV-MARRA 000941 EFTA00230765 e•;;S",:%%::: - - • /len" Case 9:08-cv-80736-KAM Document 60 Entered on FLSD Docket 04/07/2011 Pag
Entities connected to both Holy Land Foundation and Steinger

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Jeffrey Epstein
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George W. Bush
PERSONJames Eisenberg
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Kenneth Marra
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Anderson
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LOCATIONDow Jones & Co.
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Scarlett Johansson
PERSONthe District Court Clerk's Office
ORGANIZATIONthe Court of Appeals
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ORGANIZATIONJane Doe
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Michael Douglas
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Barry Diller
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William Shakespeare
PERSONClerk's Office
ORGANIZATIONSuperior Court
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