Berger & Grossmann UP, 814 F.3d 132 (2d Cir. 2016) (weighing value of public disclosure of complaint against privacy interests in favor of access); Newsday LLC v. Cnty. of Nassau, 730 F.3d 156 (2d Cir. 2013) (finding First Amendment right of access to contempt proceeding); N.Y. Civil Liberties Union v. N.Y.

form based in federal common law."' United States v. Doe, No. 3:19-MC-00027-AWT, 2019 U.S. Dist. LEXIS 36605, at *3 (D. Conn. Mar. 6, 2019) (quoting Newsday LLC v. County of Nassau, 730 F.3d 156, 163 (2d Cir. 2013)). In the Second Circuit, courts utilize two methods approaching the First Amendment right. Do

Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) passim N.Y. Civil Liberties Union v. N.Y.C. Transit Auth. (NYCTA), 684 F.3d 286 (2d Cir. 2012) 18 Newsday LLC v. Cnoi. of Nassau, 730 F.3d 156 (2d Cir. 2013) 18, 20 iii EFTA00075480 Case 20-2413, Document 40, 08/20/2020, 2913550, Page5 of 74 Nixon a War

form based in federal common law."' United States v. Doe, No. 3:19-MC-00027-AWT, 2019 U.S. Dist. LEXIS 36605, at *3 (D. Conn. Mar. 6, 2019) (quoting Newsday LLC v. County of Nassau, 730 F.3d 156, 163 (2d Cir. 2013)). In the Second Circuit, courts utilize two methods approaching the First Amendment right. Do

power over its own records and files," United States v. Erie Cty., N Y., 763 F.3d 235, 240 (2d Cir. 2014) (quoting Nixon, 435 U.S. at 598); accord Newsday LLC v. County of Nassau, 730 F.3d 156, 163 (2d Cir. 2013). The second principle is that "balanc[ing] the public's interest in access to judicial docume

noting that the common law and First Amendment provide "related but distinct presumptions in favor of public access to court ... records") (quoting Newsday LLC v. Cnty. Of Nassau, 730 F.3d 156, 163 (2d Cir. 2013)). Both regimes protect the values of transparency and accountability in the judicial process th