Tserpelis v. BDO USA PC

Background

Eleni Tserpelis, also known as Eleni Lagos, through counsel, filed a renewed request for permission to submit an unredacted amended complaint under seal. The request followed an earlier filing and an order identified as Docket 29. The public amended complaint, identified as Docket 30, contained redactions; the proposed unredacted version was identified as Docket 31.

Reasons for the Request

The request stated that the unredacted amended complaint contained confidential, proprietary, and commercially sensitive information. The listed information included client names and details about BDO USA PC’s client relationships, partnership structure, revenue targets, client accounts, internal personnel matters, and business-development strategies. It specifically identified redacted revenue information concerning BDO’s New York Metro ASC 740 market, emails containing client information, and a text message containing client names.

The request explained that counsel had exchanged communications about proposed redactions before the original complaint was filed. It argued that courts may restrict public access to judicial records when disclosure of business information could harm a litigant’s competitive position, and that the confidential client and business information justified sealing the complete version while preserving public access to the redacted allegations.

Ruling

The court granted the request to file the unredacted amended complaint under seal. The order thus permitted the complete version to remain nonpublic while the redacted amended complaint remained the public filing. Judge Jennifer E. Willis signed the order.