David Reimann

It's the most efficient procedure to use.

Otherwise, I don't know what exactly the suggestion is for Mr. Robinson's team that we're supposed to do from here on out.

But it kind of sounds like just this sort of ad hoc show up any time you happen to see something on the public docket that might affect the public's rights.

And that's just not the orderly way that this typically happens.

The other thing, as I've mentioned in our papers, that it does...

is it allows for the media to be able to take an appeal of a closure issue without having to rely on the court's extraordinary red jurisdiction.

And that was what they had to do in either Kern's Tribune or Bullock, where the media was not granted party status.

And it is the situation that happened in FL where they had to review her claim regarding records under extraordinary writ jurisdiction rather than invoking their appellate jurisdiction because she was improperly denied limited party status.

So all of that authority supports the process that we are requesting in this case.

We think it's the most orderly way to do it.

And I'll end just by saying there's been some

discussion and especially from Mr. Robinson's attorneys about what rule it is that you need to do this under, whether Rule 24 applies.

They seem to suggest that it doesn't.

I will just point the court to two different rules that give you the authority to do what we're requesting, aside from Rule 24.

Rule 24 is in the civil procedure rules, but Rule

81, and particularly subsection F of that rule, says that the rules of civil procedure govern in criminal proceedings where they don't conflict with a rule of criminal procedure.

That's the case with Rule 24.

That's why courts in criminal cases have relied on that rule.

The other one is Rule 31, and that's in the criminal procedure rules.

And that gives this court the discretion, if it's not inconsistent with the rules, to fashion remedies.