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orum in which to disclose these facts. *4 Although there is no case directly on this point, the present question comes fully within the holding of Barron, which thoroughly considered the com- petition between the people's interest in public courts and the personal interest in private facts. In effect
lic identification. However, Barron teaches that this is the wrong question because it overlooks the higher purpose of openness in the courts. In Barron, a case involving privacy concerns inher- ent in a divorce case, the court strongly reaffirmed the presumption that Florida civil courts are open.
ong presumption in favor of public ac- cess to such matters." Sentinel Communications Co. I. Watson, 615 So.2d 768, 770 (Fla. 5th DCA 1993) (citing Barron'. Florida Freedom Newspapers, Mc., 531 So.2d 113 (Fla.1988)). This presumption rests on the most fundamental values of American government. (ID 2
RT OF APPEAL FOURTH DISTRICT OF FLORIDA CASE NO. 4D09-2554 JEFFREY EPSTEIN, Petitioner, vs. STATE OF FLORIDA1LM BEACH NEWSPAPERS, INC., ., AND B.B., Respondents. SUPPLEMENTAL APPENDIX TO PALM BEACH NEWSPAPERS, INC., d/b/a THE PALM BEACH POST'S RESPONSE TO EMERGENCY PETITION FOR WRIT OF CERTIO
orum in which to disclose these facts. •4 Although there is no case directly on this point, the present question comes fully within the holding of Barron, which thoroughly considered the com- petition between the people's interest in public courts and the personal interest in private facts. In effect
rong presumption in favor of public ac- cess to such matters." Sentinel Communications Co. I Watson, 615 So.2d 768, 770 (Fla. 5th DCA 1993) (citing Barron I Florida Freedom Newspapers, Inc., 531 So.2d 113 (Fla.1988)). This presumption rests on the most fundamental values of American government. O200
lic identification. However, Barron teaches that this is the wrong question because it overlooks the higher purpose of openness in the courts. In Barron, a case involving privacy concerns inher- ent in a divorce case, the court strongly reaffirmed the presumption that Florida civil courts are open.
APPEAL FOURTH DISTRICT OF FLORIDA CASE NO. 4D09-2554 JEFFREY EPSTEIN, Petitioner, vs. STATE OF FLORIDA, PALM BEACH NEWSPAPERS, INC., E.W., AND B.B., Respondents. SUPPLEMENTAL APPENDIX TO PALM BEACH NEWSPAPERS, INC., d/b/a THE PALM BEACH POST'S RESPONSE TO EMERGENCY PETITION FOR WRIT OF CERTIO
Va. 2007) 23 United States v. Kooistra, 796 F.3d 1390 (11th Cir. 1986) 9 State Cases Anderson v. E.T., 862 So. 2d 839 (Fla. 4th DCA 2003) 8 Barron v. Florida Freedom Newspapers. lac., 531 So. 2d 113 (Fla. 1988) 10 Combs v. State, 436 So. 2d 93 (Fla. 1983) 8 Doe v. Museum of Science and His
APPEAL FOURTH DISTRICT OF FLORIDA CASE NO. 4D09-2554 JEFFREY EPSTEIN, Petitioner, vs. STATE OF FLORIDA, PALM BEACH NEWSPAPERS, INC., E.W., and B.B., Respondents. Pending in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida, Case Nos. 2006 CF 9454AMB, 2008 CF 938 1 AMB PALM
the news media, the Post has a right to intervene in criminal proceedings for the limited purpose of seeking access to proceedings and records. See Barron v. Florida Freedom Newspapers, Inc., 531 So. 2d 113, 118 (Fla. 1988) (news media have standing to challenge any closure order); Miami Herald Publ'a
d his partner, Mr. Luttier, had a court reporter and a videographer present. Additionally, Mr. Hill on behalf of C.M..A., Adam Langino on behalf of B.B., William Berger on behalf of three Plaintiffs were present for the deposition. 3 09/12/2019 Page CONFIDENTIAL Agency to Agency Requet 19-411 SDN
mper: or me news a, the Post has a right to intervene in criminal , I i is fOr the hotbed punxise of seeking access to proceedings 04 records. gm Barron v • '2 1 • . • I : . • ! ' ' Florida Freedom Neivspatates? Inca 531 Sc. 2d 113,118 (Fla. 1!88Vners media have standing , L. i. : • . 1
) Non-party M.'s Motion to Vacate Order Sealing Records and Unseal Records b) Palm Beach Post's Motions to Intervene and Petition for Access c) B.B.'s Motions to Intervene and for an Order to Unseal Records d) Jeffrey Epstein's Motion to Make Court Records Confidential A hearing was conducted o
D. Va. 2007) 23 United States'. Kooistra, 796 F.3d 1390 (11th Cir. 1986) 9 State Cases Anderson I E.T., 862 So. 2d 839 (Fla. 4th DCA 2003) 8 Barron'. Florida Freedom Newspapers, Inc., 531 So. 2d 113 (Fla. 1988) 10 Combs State 436 So. 2d 93 (Fla. 1983) 8 Doe I Museum of Science and History
TA00233599 3. INTERESTED PERSONS: Judith Stevenson Arco of State Attorney's Office--West Palm Beach (counsel for respondent, State of Florida) B.B. (non-party intervener) William J. Berger of Rothstein Rosenfeldt Adler (counsel for non-party intervener, E.W.) Honorable Jeffrey J. Colbath (c
Entities connected to both Barron and B.B.

Jeffrey Epstein
PERSONSpencer Kuvin
PERSON
George W. Bush
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONRobert D. Critton
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
Palm Beach Gardens
LOCATIONScott Rothstein
PERSONJane Doe
PERSON
United States
LOCATION
Donald Trump
PERSON
Alexander Acosta
PERSONMichael J. Pike
PERSON
Scarlett Johansson
PERSONGoldberger & Weiss
ORGANIZATIONLeopold-Kuvin
ORGANIZATION
Tampa
LOCATIONPalm Beach County Courthouse
LOCATION