De Sangosse Agroquimica Ltda. v. JDGU Investment LLC

Background

De Sangosse Agroquimica Ltda. sought permission to file under seal a declaration by Cristian Gallorini and its exhibits in support of De Sangosse’s motion for partial summary judgment. The exhibits included financial statements of JDGU Investment LLC, Juan Diego Gonzalez, and other defendants. One exhibit also included a driver’s license and a redacted copy of a Social Security card. The motion letter stated that Gonzalez consented to the requested relief.

Court’s analysis

The court explained that judicial documents are generally subject to a common-law presumption of public access, although courts must balance that presumption against competing interests. After reviewing the exhibits, the court determined that some materials did not need to be sealed in full. Written discovery responses contained only limited references to complete bank-account numbers, which could be redacted. Email exchanges with non-parties also could be redacted rather than sealed entirely.

The court further referred counsel to the federal E-Government Act, Federal Rule of Civil Procedure 5.2, and the Southern District of New York’s electronic-filing privacy policy. Those rules allow financial-account numbers to be redacted to show only the last four digits, and allow individual financial information and personally identifying information to be redacted without prior court approval.

Ruling

The court stated: “Application DENIED without prejudice to renewal.” It ordered De Sangosse to refile the declaration and attached exhibits by March 4, 2025, with redactions allowed without court permission and with any request for further redaction or targeted sealing made under the court’s rules. The clerk was directed to terminate docket entries 96 and 98. Judge Margaret M. Garnett did not decide the underlying motion for partial summary judgment in this order.