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20 21 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 15 of 64 14 H2G8GIUC THE COURT: Anything further? MR. WOLMAN: I am surprised by the question of standing. Nothing in any of the opposition suggests that my client is not a member of the Fourth Estate. Nothing in the opposition suggests that this is not a newsworthy case. There have been plenty of articles about Mr. Epstein, about this entire proceeding. This has been in the media. So my client is just another journalist looking to find out here what's going on. Honestly, I am litigating a little bit with one arm tied behind my back because I am being told that the summary judgment motions and papers have information about all these other minors. I wouldn't know that, your Honor. The motion for summary judgment is redacted, pages 1 to 68. Every single exhibit, the opposition, the reply, this is all redacted. This is not part of the public record. The public cannot examine it. Regardless of my client's relationship with Professor Dershowitz does not negate his standing as a member of the media looking to report on a newsworthy case. If there are particular materials in the summary judgment motion or opposition that are proper to be sealed, we recognize that, but we don't know what they are in order to make that analysis. They are putting the cart before the horse saying it should be sealed or remain sealed when they haven't made a showing of SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300