Absolute Resolutions Investments, LLC v. Citibank, N.A.
- Garnett
- 1:22-cv-02079
- U.S. District Court · Southern District of New York
- 3
In Absolute Resolutions Investments v. Citibank, Judge Garnett granted Citi’s request to seal two exhibits containing personal and competitively sensitive information.
Citibank, the account holders whose personal information appeared in the spreadsheets, the parties seeking or opposing discovery, and members of the public seeking access to judicial documents.
What happened
Absolute Resolutions Investments, LLC v. Citibank, N.A. involved Citibank’s request to file two spreadsheets under seal in connection with discovery-related letter motions. Citibank said the spreadsheets contained account-holder information and commercially sensitive information about accounts sold to Cavalry and purchased by other debt buyers.
Citibank argued that sealing was justified because the exhibits included personal information, account details, pricing information, and other data that could cause financial or competitive harm if disclosed. Absolute consented to filing the exhibits under seal.
The court granted Citibank’s request, finding that Citibank’s interest in protecting competitively sensitive information outweighed the public’s interest in access to the documents. Judge Margaret M. Garnett also directed the Clerk of Court to terminate Docket Nos. 91 and 98.
The detailed version
- Absolute Resolutions Investments, LLC v. Citibank, N.A. · No. 1:22-cv-02079
- Garnett
- Apr. 29, 2025
Background
Citibank asked the court for permission to file two exhibits under seal in support of its response to Absolute’s letter motion seeking production of documents from Cavalry and Cavalry’s motion to quash. The exhibits were Excel spreadsheets produced to Absolute during discovery.
Citibank represented that the spreadsheets included information about 264 accounts involved in a subpoena directed to Cavalry, as well as information about accounts purchased by other Citibank debt buyers. The information included account-holder personal information, payment dates, account balances at the time of sale, auction types, winning percentage rates, and pricing-related information. Citibank also stated that certain account numbers and home addresses were redacted from the proposed filings.
Court’s Analysis
The court recognized a common-law presumption that the public may access judicial documents. It also stated that courts routinely seal documents to prevent disclosure of confidential or sensitive business information. After examining the documents and considering Citibank’s representation that they contained competitively sensitive information, the court found that Citibank’s interest in sealing the information outweighed the public’s interest in access.
Disposition
Judge Margaret M. Garnett granted Citibank’s request to file the two exhibits under seal. The court directed the Clerk of Court to terminate Docket Nos. 91 and 98.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.