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t seal the entire court record, as happened 4 EFTA00600018 Case 9:08-cv-80736-KAM Document 295 Entered on FLSD Docket 01/26/2015 Page 5 of 18 in Brown and Wilson. Instead, because we are seeking only that the Court temporarily seal discrete documents rather than complete pleadings or an entire doc
ut tempering or censoring their plea/settlement communications to avoid making statements that could later come back to haunt their clients in TMZ, the National Enquirer or the grocery store tabloids. c. The Harm Extends To Mr. Epstein, His Counsel, And Beyond We know of no case that has authorized the wholesale pu
t seal the entire court record, as happened 4 EFTA00210720 Case 9:08-cv-80736-KAM Document 295 Entered on FLSD Docket 01/26/2015 Page 5 of 18 in Brown and Wilson. Instead, because we are seeking only that the Court temporarily seal discrete documents rather than complete pleadings or an entire doc
ut tempering or censoring their plea/settlement communications to avoid making statements that could later come back to haunt their clients in TMZ, the National Enquirer or the grocery store tabloids. c. The Harm Extends To Mr. Epstein, His Counsel, And Beyond We know of no case that has authorized the wholesale pu
owever, in response to a question by Senator Hank Brown, Professor Hill testified that she had disagreed
next notorious masturbation enhancer. In the eyes of the media—from NBC News to MWghtline, from TIME magazine to People, from the New York Times to the National Enquirer, from the Washington Post to Entertainment Tonight—| am purely a commodity. Naturally, | believe in the First Amendment, so I’ m against censorship.
EFTA00582791 circumstances or particularized needs@ standard because we are not asking that the Court seal the entire court record, as happened in Brown and Wilson. Instead, because we are seeking only that the Court temporarily seal discrete documents rather than complete pleadings or an entire doc
ut tempering or censoring their plea/settlement communications to avoid making statements that could later come back to haunt their clients in TMZ, the National Enquirer or the grocery store tabloids. c. The Harm Extends To Mr. Epstein, His Counsel, And Beyond We know of no case that has authorized the wholesale
Entities connected to both Julie K. Brown and the National Enquirer

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONDarren Indyke
PERSONLeon Black
PERSON
Donald Trump
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSON
Samantha Power
PERSON
Prince Charles
PERSON
Virginia Giuffre
PERSON
Joe Biden
PERSON
Michael Jackson
PERSON
Scarlett Johansson
PERSON
Bloomberg L.P.
ORGANIZATION
John F. Kennedy
PERSON
Hillary Clinton
PERSON
Bradley Edwards
PERSON
Michael Cohen
PERSON