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Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page19 of 25 implicated by the unsealing. Accordingly, we remand the cause to the District Court to conduct such a particularized review and unseal all documents for which the presumption of public access outweighs any countervailing privacy interests. D. Protecting the Integrity of Judicial Proceedings While we disagree with the District Court’s disposition of the motions to unseal, we share its concern that court files might be used to “promote scandal arising out of unproven potentially libelous statements.” We therefore describe certain methods courts can employ to protect the judicial process from being coopted for such purposes. The Supreme Court has explained that “[e]very court has supervisory power over its own records and files” to ensure they “are not used to gratify private spite or promote public scandal” or “serve as reservoirs of libelous statements for press consumption.”°? This supervisory function is not only within a district court’s power, but also among its responsibilities. In practice, district courts may employ several methods to fulfill this function. They may, for instance, issue protective orders forbidding dissemination of certain material “to protect a party or person from annoyance, embarrassment, oppression, or undue 38 Giuffre, 325 F. Supp. 3d at 447. % Nixon, 435 U.S. at 598 (internal quotation marks). 19