Not the Bee, LLC’S Motion to Intervene and Motion to Unseal - Criminal No. 24-CR-00298 - Filed on 11/25/24

Aug 22, 2026

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Not the Bee, LLC moves to intervene in a federal criminal case for the limited purpose of seeking public access to sealed docket entries. The motion argues that sealed filings at docket numbers 101, 104, 107, and 108 were sealed without adequate justification and without submissions establishing good cause for sealing. It contends the government fails to meet the heightened requirements needed to suppress the public’s First Amendment right of access to criminal proceedings and the press’s right to gather news, and requests unsealing and related court orders.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages11

Reading Time28 min

AccessFree to download

Motion Overview

Request to Intervene and Unseal

Background

Proposed Intervenor

Relevant Case Background

Argument

Standing to Challenge Sealing

Case 4:24-cr-00298 Document 117 Filed on 11/25/24 in TXSD Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION UNITED STATES OF AMERICA V. EITHAN HAIM §§ §§ § Criminal No. 24-CR-00298 NOT THE BEE, LLC’S MOTION TO INTERVENE AND MOTION TO UNSEAL Not the Bee, LLC (“Not the Bee”) moves to intervene in this action for the limited purpose of moving to unseal the following docket entries on the ground that they have been sealed without sufficient justification: Dkt. Nos. 101, 104, 107, and 108 (the “Sealed Filings”) . I. Introduction This case warrants maximum transparency. The unprecedented investigation and prosecution of Dr. Eithan Haim has been covered by many media outlets and news websites, including Not the Bee, and is a topic of conversation among prominent politicians, intellectuals, and legal commentators, as well as the public at large. The press and public have demonstrated substantial interest in Dr. Haim’s whistleblowing, the medical procedures on minors that are the subject of his revelations, the misconduct by the government in pursuing this prosecution, and the various setbacks that the government has faced in attempting to criminalize Dr. Haim’s efforts to bring to light the illegal conduct of Texas Children’s Hospital. Case 4:24-cr-00298 Document 117 Filed on 11/25/24 in TXSD Page 2 of 11 Not the Bee operates a news, opinion, and entertainment website and is interested in publishing news coverage of Dr. Haim’s case to draw attention to the absurd fact that when a doctor exposed highly unethical medical practices, it was the doctor who faced criminal prosecution, despite his whistleblower status. As a member of the press and public, Not the Bee has standing to challenge the sealing of documents so that it may obtain access to information concerning judicial proceedings. The government has not demonstrated any legitimate grounds to seal the documents, let alone the heightened grounds necessary to suppress the public’s First Amendment right of access to criminal proceedings and the press’s right to gather the news. For these reasons, Not the Bee respectfully asks the Court to grant its motion to intervene for the limited purpose of moving to unseal, grant its motion to unseal, and order that docket entry numbers 101, 104, 107, and 108 be unsealed. II. Background a. Proposed Intervenor Not the Bee operates the website [notthebee.com](notthebee.com), which is a humor-based news, opinion, and entertainment site from the creators of The Babylon Bee and Disrn. The Babylon Bee, Not the Bee’s sister website, uses satire and humor as a means of commenting on culture, politics, and current events. In a related vein, Not the Bee publishes news headlines involving events that are so outrageous that they sound like satire, even though they involve real-world occurrences. By publishing Case 4:24-cr-00298 Document 117 Filed on 11/25/24 in TXSD Page 3 of 11 news articles on its site, Not the Bee engages in commentary about the events in question and draws attention to the ridiculousness or absurdity of such events. b. Relevant Case Background Following a hearing at which the Court entertained the defense’s motion to dismiss the superseding indictment on multiple grounds (some of which the government did not contest)– and despite the government’s representation at this hearing that it would not supersede again – the government filed a second superseding indictment. ECF 100, 110. Around this time, the government, without any apparent justification, made three sets of filings under seal. First, immediately after the hearing and before the second superseding indictment was filed, a filing was made under seal, with no description. ECF 101. Second, a government attorney filed a motion to withdraw as counsel of record for the United States. Though the filing was entirely under seal (ECF 104) , the court then granted the motion and provided the title of the

FAQs

What is Not the Bee, LLC asking the court to do?

Not the Bee asks to intervene for the limited purpose of moving to unseal and to have specified sealed docket entries unsealed.

Which docket entries does the motion seek to unseal?

The motion seeks unsealing of Dkt. Nos. 101, 104, 107, and 108.

On what grounds does the motion challenge sealing?

The motion asserts the filings were sealed without sufficient justification, with no showing of good cause and no sealing argument meeting the heightened standard tied to First Amendment access rights.

Aug 22, 2026

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