t closure would prevent and, second, reasonable alternatives to closure cannot adequately protect the defendant's fair trial rights.'" Id. (quoting ABC, Inc. v. Stewart, 360 F.3d 90, 98-99 (2d Cir. 2004)). "The Second Circuit has explained that the party seeking to restrict press access bears a `heavy' b

E. Epstein, individually, and as President and Chief Executive Officer of The Financial Trust Company, The Financial Trust Company, XYZ Corp. and ABC, Inc. Defendant. X Index No. RELATED ACTIONS: Case No. 94 CR 213 (RWS) Case No. 95 CR 213 (RWS) JUDGE ROBERT W. SWEET COMPLAINT Ray Marques and

the fraudulent nature. Defendant TFTC has misappropriated or converted such monies, securities and proceeds. 13. Defendants XYZ Corp. ("XYZ") and ABC, Inc. ("ABC") are fictitious names. Plaintiffs reserve the right to amend this Complaint as a result of pleading fictitious parties. Defendants XYZ and A