Hurlock v. Ventures
- Rochon
- 1:25-cv-03891
- U.S. District Court · Southern District of New York
- 3
In MHurlock v. Kelsier Ventures, Judge Rochon denied sealing and denied Defendant Chow’s extension request as moot.
The ruling affects the plaintiffs’ effort to restrict public access to the CI Materials, Defendant Chow’s request for additional time, the other defendants’ access to the materials, and the public’s access to the court record.
What happened
In MHurlock v. Kelsier Ventures, the plaintiffs asked to keep certain materials about an unnamed confidential source out of the public record and proposed limits on who could see them. They said disclosure could identify and endanger the source and could increase the risk that information would be deleted.
The court found that the plaintiffs had offered only speculative and conclusory claims about the safety risk. It also said that a possible future effect on employment was not enough to overcome the public’s right to access court records.
Judge Jennifer L. Rochon denied the plaintiffs’ motion to seal at Dkt. 187. She also denied Defendant Chow’s motion for an extension of time at Dkt. 191 as moot.
The detailed version
- Hurlock v. Ventures · No. 1:25-cv-03891
- Rochon
- Oct. 3, 2025
Background
The plaintiffs sought permission to file certain supporting materials under seal and requested a narrowly limited protective order. They called the materials “CI Materials” and said they concerned alleged coordination involving Defendants Meteora and Kelsier, operational direction by Defendant Chow, business dealings, contractor selection, and similar methods allegedly used for other tokens. The plaintiffs said the materials were being submitted to support their claim of irreparable harm at that stage, not for a final decision on the underlying merits.
The plaintiffs argued that the materials could identify an unnamed third party who had assisted with the litigation. They said that even short quotations, platform identifiers, account handles, message identifiers, or precise timestamps could allow the person to be identified and could enable deletion of relevant information. They proposed alternatives including public versions without identifying details, court-only review, and limited access for outside counsel. The opinion states that counsel for Kelsier Ventures and the other defendants did not oppose filing under seal but opposed filing the materials outside the other parties’ access; counsel for Defendant Chow objected to the proposed court-only and outside-counsel-only arrangements.
Court’s Analysis
Court records are generally presumed to be accessible to the public. A party seeking to restrict access must provide specific facts showing that disclosure would cause a sufficiently serious injury. The court concluded that the plaintiffs’ assertions about the witness’s safety were speculative and conclusory and therefore insufficient to justify denying public access to the record.
The court also stated that a possible future negative effect on employment was not a sufficiently important interest to overcome the presumption of access. The opinion did not make a merits determination about the plaintiffs’ underlying claims or the alleged conduct involving the defendants.
Ruling
Judge Jennifer L. Rochon denied the plaintiffs’ motion to seal at Dkt. 187. The court denied Defendant Chow’s motion for an extension of time at Dkt. 191 as moot. The order does not state that either motion was denied with or without prejudice.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.