Doolittle v. Bloomberg L.P.

Background

The court had previously issued an order addressing Abigail Doolittle’s and Bloomberg L.P.’s pending motions to seal. Doolittle then asked for clarification about what parts of exhibits attached to the parties’ motions concerning expert testimony could remain sealed and whether the parties could redact parts of their legal memoranda that quoted or summarized sealed exhibit material.

The materials at issue included reports and deposition transcripts from Dr. Seltzer and Dr. Lieberman, PTSD checklists for the Diagnostic and Statistical Manual of Mental Disorders, Fifth Edition, completed by Doolittle, and office notes from Doolittle’s physicians.

Court’s Clarification

The court stated that the expert reports contained sensitive medical information and information not relevant to the litigation, so they could remain under seal at this stage. For the deposition transcripts, Doolittle could propose targeted redactions for excerpts discussing sensitive medical information or intimate details of her life that were not directly connected to the case.

The court also allowed Doolittle to file the PTSD checklists under seal and allowed the physicians’ office notes to remain under seal. In summary, the expert reports, PTSD checklists, and office notes could temporarily remain sealed while the court reached a final decision on the underlying substantive motions.

The court further allowed the parties to refile their legal memoranda with redactions covering portions that directly quoted or summarized sealed exhibit material. It noted that some or all of the information could later be unsealed in a future opinion or at trial, because the materials were part of judicial documents. Judge Jennifer L. Rochon issued the memorandum opinion and order on March 31, 2025.