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20 21 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 13 of 64 12 H2G8G1IUC H HE COURT: Anything further? MS. SCHULTZ: Before you are going to reach the merits going to the sealing order, the protective order, there is no standing to intervene in this case. H HE COURT: Thank you. Anything else? MS. SCHULTZ: Yes, if you don't mind, your Honor. It fails for other reasons under the law. In the entire motion and reply brief, it is wholly bereft of case law in which a motion to intervene and publish confidential information has been granted in a case with circumstances like this at all. Here, there are clear and compelling reasons for the sealed documents to remain sealed. They involve the sexual abuse and sexual trafficking of minors. Both parties in this case and the Court in its March 17, 2016 hearing articulated clear and compelling reasons why these records should be sealed. Contrary to the Bernstein case cited by the purported intervenor, where records were unsealed after settlement, not weeks prior to trial, these documents were not sealed because of some pedestrian reason like an alleged kickback scheme. There can hardly be a more compelling reason to seal documents than those that depict the sexual abuse and sexual trafficking of plaintiff, other minors and other young women. Here, there is no showing why some unspecified SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300