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S.D.N.Y.Procedural orderFiled June 24, 2025

Bhagat v. Shah

Judge
Valerie Caproni
Docket
1:24-cv-01424
Court
U.S. District Court · Southern District of New York
Pages
12
Civil ProcedurePro Se
In one sentence

In Bhagat v. Shah, Judge Tarnofsky blocked Defendant’s emails, warned her about public financial filings, and deferred review of an undocketed submission.

Who this affects

Pro se Defendant Anuja Sharad Shah is barred from emailing the judge’s chambers, admonished and warned about filing confidential financial information publicly, and told that her undocketed submission will not be reviewed until docketed. Plaintiff Viral Bhagat’s request to protect his financial records is discussed, but this order does not decide the merits of that request.

What happened

In Bhagat v. Shah, Plaintiff Viral Bhagat and Defendant Anuja Sharad Shah, both representing themselves, sent communications directly to the judge’s chambers. Bhagat asked the court to temporarily seal financial records that Shah had filed publicly. Shah responded that the matter was not urgent and challenged Bhagat’s direct communication with chambers.

The court instructed its courtroom deputy clerk to block Shah’s email communications to chambers. It also warned Shah again not to file Bhagat’s confidential financial information publicly without first asking for permission to file it under seal. The court warned that another violation of this or another court order could lead to an order requiring Shah to explain why she should not be sanctioned. The court also said it would not review Shah’s other submission until it was formally docketed through the court’s Pro Se Intake Unit.

Judge Robyn F. Tarnofsky issued the order on June 24, 2025. This order addressed communications and filing procedures; the opinion text does not itself decide the merits of the sealing or unsealing requests.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Bhagat v. Shah · No. 1:24-cv-01424
Judge
Valerie Caproni
Date
June 24, 2025

Background

The court received undocketed communications from pro se Plaintiff Viral Bhagat and pro se Defendant Anuja Sharad Shah. Bhagat’s communication asked the court to temporarily seal financial documents that Shah had filed on the public docket, including tax and other financial records identified as ECF 394-1 through 394-6. Shah’s response argued that the matter was not urgent, criticized Bhagat’s direct communication with chambers, and sought denial of Bhagat’s sealing and sanctions request and approval of Shah’s motion to unseal.

Court’s actions

Judge Tarnofsky distinguished between an urgent request to restrict public access to documents already filed and a non-urgent response explaining why the documents should remain public. The court found Shah’s communication non-urgent and instructed the courtroom deputy clerk to block all email communications from Shah to chambers.

The court stated that it had previously warned Shah that tax returns should not be filed on the public docket without a request to seal and that future violations could lead to sanctions. Because Shah had again filed Bhagat’s tax and other financial documents publicly without complying with the court’s prior instructions, the court admonished Shah for a second time. It directed her to follow the court’s procedures for requesting permission to file confidential information under seal and warned that another violation of that or any other court order could result in an order requiring her to explain why she should not be sanctioned.

The court also declined to review another submission that Shah had emailed to chambers because she had already sent it to the Pro Se Intake Unit. The court stated that it would not review such material until it was docketed.

Disposition and scope

The order blocks Shah’s email communications to chambers, issues a second admonishment and warning concerning public filing of confidential information, and defers review of the undocketed submission. The opinion text does not itself state a disposition of the merits of the sealing or unsealing requests. The opinion is signed by Robyn F. Tarnofsky, although the supplied case metadata identifies Valerie Caproni as the judge.

The authoritative version

Read the full 12-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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