On Saturday, The New York Daily News released court documents submitted by Dr. Jamie Naughright's lawyers from 2003 that detailed an incident that took place at Tennessee in 1996 in which Naughright accuses Peyton Manning of placing his "naked butt and rectum" on her face. Within those documents, there's a noticeable portion that is under seal.
Here's the reason, from page 10 of the document:
In the fall of 1994, an incident occurred involving Peyton Manning which will not only explain the genesis for Peyton Manning's dislike for Dr. Naughright but will be relevant to understanding the 1996 incident Peyton Manning writes about in the book Manning.