People of the State of New York v. Early Warning Services

Background

The New York Office of the Attorney General filed a complaint in New York state court alleging that Early Warning Services, LLC failed to safeguard the Zelle peer-to-peer payment network from fraud. The publicly available complaint included redactions, while an unredacted version was submitted under seal. The state court temporarily sealed the unredacted complaint and set deadlines for briefing about which portions should remain sealed.

Early Warning removed the action to the Southern District of New York on September 12, 2025. It argued that the state court’s temporary sealing order remained effective after removal under 28 U.S.C. § 1450, which provides that state-court orders entered before removal remain in force until the federal district court dissolves or modifies them. Early Warning asked the federal court to file the unredacted complaint under seal while it prepared a later motion explaining why some portions should remain sealed.

Ruling

Judge J. Margaret M. Garnett granted the request. Consistent with the state court’s order, the court ordered that the unredacted complaint be filed under seal. The court also adopted this briefing schedule: Early Warning must file a letter motion of no more than five pages explaining why the unredacted complaint should remain sealed by September 29, 2025; the New York Office of the Attorney General may respond by October 13, 2025. The order addressed sealing and scheduling only; the opinion does not decide the underlying allegations or the ultimate sealing question.