Gonzalez v. Ahern
- Jacquelyn Corley
- 3:19-cv-07423
- U.S. District Court · Northern District of California
- 3
In Gonzalez v. Ahern, Judge Corley denied plaintiffs’ motions to seal proposed hearing exhibits because they lacked required justification and rule compliance.
The ruling affected the plaintiffs’ efforts to seal proposed hearing exhibits, the County’s opposition to those requests, Mr. Geyer because of the sensitive information in one filing, and the public’s access to court records.
What happened
In Gonzalez v. Ahern, the plaintiffs filed three motions asking the court to keep documents secret before an evidentiary hearing about enforcing a settlement agreement. The proposed materials included a retainer agreement, an email, a declaration, and other documents.
The court said the plaintiffs had to show strong reasons for secrecy and follow the court’s local sealing rule. It found that the motions did neither: they did not explain why particular documents should be sealed, and two motions did not discuss the documents at all. The court also said attorney-client privilege generally did not protect the identity of a lawyer’s clients or the nature of fee arrangements.
Judge Jacquelyn Corley denied the plaintiffs’ motions. The court said it would address whether Mr. Geyer waived attorney-client privilege at the evidentiary hearing, and it kept one filing locked because some attachments contained sensitive personal information and appeared unrelated to the dispute.
The detailed version
- Gonzalez v. Ahern · No. 3:19-cv-07423
- Jacquelyn Corley
- Aug. 18, 2025
Background
Before an August 19, 2025 evidentiary hearing on the County’s motion to enforce a settlement agreement, plaintiffs filed three administrative motions to seal documents that their counsel apparently intended to use as hearing exhibits. The first motion sought to seal a retainer agreement, an email, and Eric Wayne’s declaration. The second appeared to seek a ruling that Mr. Geyer had waived attorney-client privilege and attached documents that the motion did not discuss. The third consisted of a caption page and purported consents from Shedrick Henry and Eric Rivera. The County opposed the motions.
Legal standard
The court explained that court records are presumed accessible to the public. Because the documents related to a motion to enforce a settlement agreement, the plaintiffs had to meet the “compelling reasons” standard. That required them to identify specific reasons why secrecy outweighed the public’s interest in access. They also had to follow Civil Local Rule 79-5(c), which requires sealing requests to be narrowly tailored to only material that can properly be sealed.
Court’s analysis
The court found that the plaintiffs’ motions did not show compelling reasons and did not comply with the local rule. The motions listed legal standards but did not analyze which standard applied to each document or explain why. The “fourth” and “fifth” motions did not discuss the documents at all.
The court also rejected the plaintiffs’ argument that the retainer exhibit was protected by attorney-client privilege. It stated that the identity of an attorney’s clients and the nature of the attorney’s fee arrangements generally are not confidential communications protected by that privilege.
To the extent plaintiffs’ counsel sought a ruling that Mr. Geyer waived attorney-client privilege, the court deferred that issue to the August 19 evidentiary hearing. Although the motions were denied, the court kept the filing at Docket No. 571 locked from public access because some attachments contained Mr. Geyer’s sensitive personal information and did not appear relevant to the underlying dispute.
Disposition
Judge Jacquelyn Corley denied the plaintiffs’ three administrative motions to seal. The court separately stated that it would discuss the locked filing with counsel at the hearing and address the alleged privilege waiver there.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.