B. No Basis Exists for Current Closure of the
ORGANIZATIONFederal Rule of Criminal Procedure 6
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Hearing, or a Proper Order 11 2. Closure of the Addendum Improperly Occurred without any Procedures to Protect the Right of Access at all. 12 B. No Basis Exists for Current Closure of the Non-prosecution Agreement or Its Addendum. 13 1. Petitioner Cannot Identify a Rule 2.420(cX9) Interest that Warrants Closure. 16 2. The Fede
. 16 2. The Federal Court's Decisions in Case No. 08-80736 (S.D. Fla. 2008) Did Not Preclude the Lower Court's Orders Unsealing the NPA. 19 3. Federal Rule of Criminal Procedure 6 Did Not Preclude the Lower Court's Orders Unsealing the NPA 21 CONCLUSION 25 CERTIFICATE OF SERVICE 26 Page 3188 CONFIDENTIAL 09/12/2019 Ag
Hearing, or a Proper Order. 11 2. Closure of the Addendum Improperly Occurred without any Procedures to Protect the Right of Access at all 12 B. No Basis Exists for Current Closure of the Non-prosecution Agreement or Its Addendum 13 1. Petitioner Cannot Identify a Rule 2.420(cX9) Interest that Warrants Closure. 16 2. The Federal
e. 16 2. The Federal Court's Decisions in Case No. 08-80736 (S.D. Fla. 2008) Did Not Preclude the Lower Court's Orders Unsealing the NPA. 19 3. Federal Rule of Criminal Procedure 6 Did Not Preclude the Lower Court's Orders Unsealing the NPA 21 CONCLUSION 25 CERTIFICATE OF SERVICE 26 EFTA00183963 TABLE OF AUTHORITIES Fe
Hearing, or a Proper Order. 11 2. Closure of the Addendum Improperly Occurred without any Procedures to Protect the Right of Access at all. 12 B. No Basis Exists for Current Closure of the Non-prosecution Agreement or Its Addendum. 13 1. Petitioner Cannot Identify a Rule 2.420(cX9) Interest that Warrants Closure. 16 2. The Federal
re. 16 2. The Federal Court's Decisions in Case No. 08-80736 (S.D. Fla. 2008) Did Not Preclude the Lower Court's Orders Unsealing the NPA. 19 3. Federal Rule of Criminal Procedure 6 Did Not Preclude the Lower Court's Orders Unsealing the NPA 21 CONCLUSION 25 CERTIFICATE OF SERVICE 26 EFTA00233610 TABLE OF AUTHORITIES Fe
Entities connected to both B. No Basis Exists for Current Closure of the and Federal Rule of Criminal Procedure 6

Jeffrey Epstein
PERSON
Alexander Acosta
PERSON
George W. Bush
PERSONFOURTH DISTRICT
LOCATIONthe Lower Court's
ORGANIZATIONJames B. Lake
PERSONThe Federal Court's
ORGANIZATIONthe Fifteenth Judicial Circuit
ORGANIZATION
Barbara Bush
PERSON
Bill Burns
PERSONRobert D. Critton
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSON
The Palm Beach Post
ORGANIZATION
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
Lauderdale
LOCATIONScott Rothstein
PERSONSpencer Kuvin
PERSONEnvtl
LOCATION