Doe v. DNA Diagnostics Center

Background

On September 25, 2025, Jane Doe filed a letter requesting a conference to help the parties finalize a settlement agreement. The court denied that request. It reminded the parties that the case management plan and scheduling order governed all deadlines, including discovery deadlines, and that settlement discussions did not automatically extend those deadlines.

On October 6, 2025, DNA Diagnostics Center, LLC and Winn Health Labs, LLC filed a motion to seal portions of Doe’s letter. Doe responded the same day.

Sealing analysis

The court applied the three-step test summarized by the Second Circuit in Mirlis v. Greer for deciding whether the presumption of public access applies to a court filing and prevents sealing. First, the court determines whether the filing is a “judicial document”—a document filed by the parties that is relevant and useful to the court’s work. Second, the court determines how much weight to give the public-access presumption. Third, the court identifies legitimate reasons against disclosure and balances them against that presumption.

The court concluded that Doe’s letter was a judicial document because the parties had filed it with the court and it was useful to the court’s process. It found that the defendants’ motion did not analyze the second and third steps. The court therefore could not find sufficient reason to overcome the presumption of public access. It stated that any renewed sealing motion must address the applicable standard.

Disposition

The court denied the request for a settlement conference. It denied the motion to seal without prejudice. The clerk was directed to terminate the motions at Docket Nos. 48 and 52.