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HOUSE_OVERSIGHT_015595

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(Fla. 2d DCA 1977) (“The judge’s statement that he had ‘cogent reasons’ for sealing the records obviously fell short of specifically setting forth the reasons why public access to these deposition was being denied.”). Moreover, Roberts and Plaintiffs cannot argue that sealing her deposition in its entirety is “the least restrictive” option, as it is most certainly the most restrictive option and one that Florida courts take very seriously. “[A] closure order must be drawn with particularity and narrowly applied.” Barron, 531 So. 2d at 117. Here, that requisite “least restrictive” application requires, at a minimum, allowing Dershowitz to use Roberts’s testimony for the limited purposes necessary in the professional judgment of his counsel to represent their client, as a matter of fairness and due process. CONCLUSION Because Dershowitz must be able to prepare his defense and any sealing order must be the least restrictive measure available, the Court should modify the Confidentiality Order to confirm that Dershowitz’s counsel may disclose Roberts’s testimony as they deem necessary in their professional judgment in order to represent Dershowitz 1n this case. 6 HOUSE_OVERSIGHT_015595

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