Krimsky v. WestRock Company
- Garnett
- 1:23-cv-06252
- U.S. District Court · Southern District of New York
- 2
In Krimsky v. WestRock Company, Judge Garnett granted the consent motion to seal compensation records containing sensitive financial and business information.
Marshall Krimsky, the defendants, and members of the public seeking access to Exhibit C.
What happened
In Krimsky v. WestRock Company, Marshall Krimsky asked the court to seal Exhibit C, compensation records covering January 1, 2013, through August 31, 2023. The defendants consented to the request.
The court considered the public’s right to view court records against privacy interests and the confidentiality of business information. The records were filed in connection with a summary-judgment motion and therefore were subject to a presumption of public access.
Judge Margaret M. Garnett ruled that Krimsky’s interest in protecting his compensation information and the defendants’ business-operation information outweighed that presumption. The court granted the motion to seal Exhibit C and directed the clerk to terminate Docket No. 47.
The detailed version
- Krimsky v. WestRock Company · No. 1:23-cv-06252
- Garnett
- Apr. 8, 2025
Background
Marshall Krimsky filed a consent letter-motion asking for permission to file under seal Exhibit C to his opposition to the defendants’ motion for summary judgment. Exhibit C contained compensation records for Marshall Krimsky from January 1, 2013, through August 31, 2023. The submission stated that the exhibit included sensitive information about the defendants’ business operations and Krimsky’s personal finances and compensation. The request was made under a protective order that the parties had agreed to and the court had entered on July 16, 2024.
Legal Standard
The court explained that documents filed in connection with summary judgment are judicial documents because they directly affect the court’s decision. Judicial documents generally carry a presumption of public access under the common law and the First Amendment. That presumption is not absolute. Courts weigh the strength of the public-access interest against countervailing considerations, including privacy interests and business secrecy.
Ruling
Judge Margaret M. Garnett granted the consent letter-motion to seal Exhibit C. The court found that the interests in protecting sensitive information about Krimsky’s compensation and the defendants’ business operations outweighed the presumption of public access. The clerk was directed to terminate Docket No. 47.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.