Lawson v. Paramount Global and Black Entertainment Television LLC
- Ho
- 1:24-cv-03315
- U.S. District Court · Southern District of New York
- 2
In Lawson v. Paramount Global, Judge Ho denied without prejudice the parties’ request to keep dispute-related documents under seal.
The parties, including Keith Lawson, Paramount Global, and Black Entertainment Television LLC, and members of the public seeking access to the filed materials were affected. The order also addressed information concerning a third party.
What happened
In Lawson v. Paramount Global and Black Entertainment Television LLC, the parties jointly asked to file letter motions and exhibits under seal. They said the materials included confidential discovery information, employment-history information, proprietary business information, and sensitive information about a third party.
The court said the materials were connected to a dispute and therefore were judicial documents, which generally carry a presumption of public access. The court found that the parties’ broad request did not explain the need for sealing in enough detail or propose narrowly tailored redactions.
Judge Ho denied the sealing request without prejudice. He allowed the parties to file a renewed motion by October 30, 2025, with specific reasons and proposed redacted versions; otherwise, the documents would be unsealed, and the Clerk of Court was directed to terminate ECF No. 45.
The detailed version
- Lawson v. Paramount Global and Black Entertainment Television LLC · No. 1:24-cv-03315
- Ho
- Oct. 23, 2025
Background
The parties jointly requested permission to file certain letter motions and supporting exhibits under seal. The materials concerned a dispute about whether Fania N. Washington, Esq., Senior Vice President, Employment Law, acted as a fact-finder and investigated Plaintiff Keith Lawson. The parties asserted that the materials included documents designated as confidential discovery material, information about Lawson’s employment history, Defendants’ confidential and proprietary information, and sensitive information about a third party. They also cited Defendants’ contractual confidentiality obligations to that third party.
Court’s Analysis
The court treated the materials as judicial documents because they were submitted in connection with a dispute. Judicial documents are subject to a presumption of public access. The court explained that sealing requires specific findings that it is necessary to protect important interests and that the sealing is narrowly tailored to that purpose.
The court recognized that interests such as third-party privacy and proprietary business information may, when properly supported, justify sealing or redaction. It stated, however, that it was unaware of authority establishing that a person’s employment history could be shielded from public disclosure merely because it appeared in a judicial document. More generally, the court found that the parties’ request for categorical sealing was not adequately explained and did not include narrowly tailored proposed redactions.
Disposition
The court denied the parties’ application without prejudice. The parties may file a renewed motion to keep the documents and attachments under seal. The renewed motion must identify the specific grounds for sealing or particular redactions, cite supporting authority, explain whether there are objections, and include proposed redacted versions for the public docket. The motion was due no later than October 30, 2025. If no such motion was filed by that date, ECF Nos. 45 and 46 were to be unsealed. If a motion was filed, the documents would remain under seal while the court considered it. The Clerk of Court was directed to terminate ECF No. 45.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.