PC v. Proujansky

Background

Goulston & Storrs PC filed a letter motion seeking an order requiring Philip Proujansky to produce unredacted versions of documents from a prior production, along with additional responsive documents concerning each of five entities identified in a July 31, 2025 letter. The requested materials included information about the entities’ affiliates, organization charts, and records from Carta that were in Proujansky’s possession, custody, or control.

Plaintiff argued that Proujansky had improperly applied substantial redactions based on his own decisions about what information was irrelevant. Proujansky responded that the redactions were limited to the entities’ corporate governance and management structure. He stated that information about the owners’ financial rights and his individual ownership interests had not been redacted.

Legal standard and analysis

The Court explained that, under New York law, judgment creditors may obtain discovery of matters relevant to satisfying a judgment. It found that Proujansky had shown that the redactions left available information about his financial rights in the entities and that the documents otherwise contained information within the scope of discovery under Federal Rule of Civil Procedure 69(a)(2) and New York Civil Practice Law and Rules § 5223.

The Court nevertheless concluded that the weight of authority in the Circuit generally does not allow a party to redact responsive and relevant documents based solely on that party’s unilateral determination that portions are irrelevant. The Court agreed that such unilateral redactions were inappropriate.

Ruling

The Court directed Proujansky to produce the unredacted versions of the requested documents within 10 days after the parties execute a nondisclosure agreement. The order addressed the requested document production and did not state that the motion was granted or denied using either of those terms.