Piccolo v. Equinox Holdings, Inc.
- Laura Swain
- 1:22-cv-09085
- U.S. District Court · Southern District of New York
- 2
In Piccolo v. Equinox Holdings, Inc., Judge Figueredo denied a request to seal an entire letter, requiring proposed redactions instead.
The defendants and plaintiff were directed to confer about redactions, while the privacy of non-party minors whose sensitive medical information appeared in the filing was affected by the sealing and redaction order.
What happened
In Piccolo v. Equinox Holdings, Inc., the defendants asked to keep a letter and its exhibit entirely sealed because they discussed sensitive medical information about minor non-parties. The plaintiff agreed to the request.
The court found that sealing some information could be appropriate, but ruled that sealing the entire letter was too broad because only a few lines concerned the sensitive information. It denied the sealing request and directed the parties to discuss and propose redactions. The documents were to remain provisionally sealed through September 27, 2024, while the proposed redactions were due September 20, 2024.
United States Magistrate Judge Valerie Figueredo also directed the Clerk of Court to terminate the sealing motion and keep the letter and exhibit provisionally sealed until the stated date.
The detailed version
- Piccolo v. Equinox Holdings, Inc. · No. 1:22-cv-09085
- Laura Swain
- Aug. 22, 2024
Background
A defendant filed a letter motion asking permission to file another letter under seal. The requested sealing concerned discussion of sensitive medical information about non-party minors. The plaintiff consented to the request.
Court’s Analysis
The court determined that the parties had shown that some material in the letter could qualify for sealing under the factors discussed in Lugosch v. Pyramid Co. of Onondaga. The court explained, however, that sealing must be narrowly tailored to protect only information that needs protection. It also considered whether partial redaction—removing only the sensitive material—was a workable alternative to sealing the entire document.
The court found the request to seal the entire letter overbroad because only a small number of lines in the letter and its exhibit discussed sensitive medical information about a non-party minor. The court concluded that redaction was a viable alternative.
Ruling and Directions
The court DENIED the letter motion at ECF No.
- It directed the parties to meet and discuss proposed redactions to the letter and exhibit at ECF No.
- The documents were to remain under seal provisionally until Friday, September 27, 2024, and the parties were directed to submit proposed redactions by Friday, September 20,
- The Clerk of Court was directed to terminate the letter motion and maintain ECF No. 33 under seal provisionally until September 27, 2024.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.