COURT

USE

ONLY

PURSUANT

TO

ARK.

SUP.

CT.

ADMIN.

ORDER

NO.

2(B)

*********************************************************

IN THE CIRCUIT COURT OF INDEPENDENCE COUNTY, ARKANSAS
LUNDEN ALEXIS ROBERTS

PLAINTIFF

vs.
ROBERT HUNTER BIDEN

DEFENDANT

Case No: 32DR-19-187
2D DIV.

MOTION TO SEAL WITH INCORPORATED BRIEF
COMES NOW the plaintiff, by and through her attorneys, LANCASTER &
LANCASTER LAW FIRM, PLLC, and for her motion states:
1.

That DNA testing has established with scientific certainty that the

defendant is the father of the plaintiff’s child.
2.

That the defendant is not expected to challenge the results of the DNA

test or the testing process.
3.

That it is anticipated that this Court will enter an order of paternity

finding the defendant to be the natural and legal father of the child who has, to date,
only been identified in pleadings to the Court as Baby Doe.
4.

That a paternity order will identify Baby Doe by the child’s full name

and date of birth.
5.

That Baby Doe’s paternal grandfather, Joe Biden, is seeking the

nomination of the Democratic Party for President of the United States of America (he
has already filed for the March 2020 Arkansas primary). He is considered by some to

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 be the person most likely to win his party’s nomination and challenge President
Trump on the ballot in 2020.
6.

That members of the Biden family either are protected or eligible to be

protected by the United States Secret Service as a direct result of Joe Biden’s political
status.
7.

That Baby Doe’s paternity could put the child and those close to the child

at risk of harm for the same reasons the Biden family is protected by the United
States Secret Service.
8.

That this Court should protect the public’s access to court records. See

Ark. Sup. Ct. Admin. Order No. 19 § 1(B)(1)(2)(3)(8)(11) (listing factors in support of
the public’s access to court records). See also id. at § 4(A)(B)(C) (“public access shall
be granted to court records” and outlining redaction procedures).
9.

That this Court should also take steps to protect Baby Doe. See id. at §

7(A)(3) (information that is excluded from public access by order or rule of the court
is confidential and may not be obtained absent a court order to the contrary).
10.

That this Court should seal the full name and date of birth of Baby Doe

as well as all other identifying information about Baby Doe that either is or may
become part of the record in this case. Pleading further, this is the least restrictive
action that will both protect the public’s access to court records while also providing
protection for Baby Doe, the child’s family, and those who interact with and love Baby
Doe.

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 11.

That this Court should order its Clerk to remove or otherwise withhold

all information about Baby Doe’s name, initials, gender, date of birth (full or partial),
and other identifying information about the child from publicly accessible records—
online or otherwise.
12.

That this Court should order that the only persons other than the Court,

its Clerk, and their staff who may obtain unredacted copies of orders or pleadings
containing identifying information about Baby Doe are the parties themselves, their
attorneys of record, or any other person who fully complies with Ark. Sup. Ct. Admin.
Order 19 § 8.
WHEREFORE the plaintiff moves this honorable Court for an order to
partially seal information about the child in this case; for attorney’s fees and costs;
and for all other just and proper relief to which she might be entitled.
Respectfully Submitted,
LANCASTER & LANCASTER
LAW FIRM, PLLC
P.O. Box 1295
Benton, Arkansas 72018
P: (501) 776-2224
F: (501) 778-6186
E: jennifer@thelancasterlawfirm.com
E: clint@thelancasterlawfirm.com
By: ________________________________
Jennifer M. Lancaster, 2011178
Clinton W. Lancaster, 2011179
CERTIFICATE OF SERVICE
I certify that a copy of the foregoing has been delivered by the below method
to the following person or persons:
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 First Class Mail

Facsimile

Email

Bart Calhoun
bcalhoun@mrcfirm.com

AOC/ECF

Hand Delivery

Jessica D. Johnston
jessica@bdjlawoffice.com

Dustin McDaniel
dmcdaniel@mrcfirm.com
on this _____ DAY of NOVEMBER, 2019.

____________________________
Clinton W. Lancaster

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