Ocampo v. HeiTech Services, Inc.
- Kandis Westmore
- 4:19-cv-04176
- U.S. District Court · Northern District of California
- 2
In Ocampo v. HeiTech Services, Inc., Judge Westmore denied both parties’ sealing motions as overbroad but allowed narrower renewed requests.
HeiTech Services, Inc. and Henry Ocampo, whose requests to seal contract and deposition materials were denied; the order also concerned the public’s access to those judicial records.
What happened
In Ocampo v. HeiTech Services, Inc., HeiTech asked to seal contract documents it said contained trade secrets, and Henry Ocampo asked to seal the same contract and related deposition testimony. The requests arose while HeiTech’s summary-judgment motion was pending, but the court did not decide that motion.
The court explained that judicial records are generally presumed open to the public. It found that sealing the entire contract was too broad because some terms did not appear to be trade secrets, including information about office hours and accessibility requirements.
Judge Kandis Westmore denied both motions to file under seal. The parties may file renewed motions within two weeks, but any renewed request must be limited to information that can properly be sealed and must explain why that information is a trade secret.
The detailed version
- Ocampo v. HeiTech Services, Inc. · No. 4:19-cv-04176
- Kandis Westmore
- July 20, 2020
Background
HeiTech Services, Inc. moved for summary judgment and separately asked to file two contract exhibits under seal: signature pages to Subcontract Agreement Modification 009 and the full subcontract modification. HeiTech asserted that the documents contained trade secrets and were contracts not publicly available. Henry Ocampo then moved to seal the same contract and deposition testimony related to it.
Legal standard
The court stated that judicial records generally carry a strong presumption of public access. A party seeking to seal records must meet the “compelling reasons” standard by providing specific reasons that outweigh the public’s interest in disclosure. The court noted that protecting trade secrets can qualify as a compelling reason, but the request must be supported and appropriately limited.
Court’s analysis
The court found that the parties’ request to seal the entire contract was overbroad. Although some contract terms might be trade secrets, the court said the entire contract did not appear to qualify. It identified examples such as the legislative mandate of the Office of Minority Health, office hours, and accessibility-compliance requirements. The court also observed that HeiTech had described several contract terms in its publicly filed summary-judgment motion, suggesting that those terms were not trade secrets.
Disposition
Judge Westmore denied the parties’ motions to file the exhibits and related materials under seal. The court allowed the parties to file a renewed motion within two weeks of the order. Any renewed motion must be narrowly tailored to information that is sealable and must explain why the information constitutes trade secrets. The opinion did not rule on HeiTech’s motion for summary judgment.
Effect
The contract materials were not sealed under these motions. The order permitted the parties to seek sealing again through narrower, better-supported requests.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.