9018. Both provisions address when a bankruptcy court may seal documents. While not before this Court, this Court does find the standard of review applied to § 107 motions illustrative of why the Debtor’s alleged harm is an insufficient ground to amend the Trustee Order. Section 107(b) and Rule 9018 do not define what constitutes “scandalous or defamatory matter.” However, courts applying these provisions have universally recognized that the fact that information may be damaging to a debtor’s reputation is not sufficient to seal a document. See, e.g., In re Neal, 461 F.3d 1048, 1054 (8th Cir.2006) (“the unintended, potential secondary consequence of negative publicity ... is regrettable but not a basis for sealing the filing.”); In re Gitto Global Corp., 422 F.3d 1, 11 (1st Cir.2005) (<HOLDING>); In re Food Management Group, LLC, 359 B.R.
recognizing power of bankruptcy court to impose sanctions on parties and counsel who willfully abuse the judicial process but not finding sanctions appropriate against debtor and his attorney for their repeated bankruptcy filings holding issue not raised in the bankruptcy court was waived on appeal holding that bankruptcy court may issue proposed findings and conclusions in a core proceeding over which the bankruptcy court does not have constitutional authority holding that the district court sitting in review of the decision of the bankruptcy court erred in concluding that plaintiffs failure to pay over taxes was willful because the bankruptcy court had made no findings on willfulness we remanded for bankruptcy court findings holding that filings in bankruptcy court may not be sealed solely because they have a detrimental impact on a partys reputation