B. Protection of undercover officers or witnesses

Under appropriate circumstances, courts have found the interest in the protection of undercover officers and cooperating witnesses to trump the presumption of openness in court proceedings and records. Thus, inAyala v. Speckard, 131 F.3d 62, 72 (2nd Cir. 1997) (en banc), the court held that “[t]he state interest in maintaining the continued effectiveness of an undercover officer is an extremely substantial interest, and the trial judge in each case was amply justified in concluding that this interest would be seriously prejudiced by requiring the officer to testify in an open courtroom.”