In Estate of Hearst (1977) 67 Cal.App.3d 777, a probate court addressed public access to periodic accountings and other material dealing with the testamentary trust of publishing magnate William Randolph Hearst, given terrorist threats to family members, including the kidnapping of granddaughter Patricia Hearst. On appeal, the Estate of Hearst court stressed the public's "legitimate interest in access to public records, such as court documents" (id. at p. 784), an interest that was best served by "temporary" limits on access, with a "continuing burden" on the party seeking to seal court records to "periodically show" the need for restricted access (id. at p. 785).