Lesnik v.Eisenmann SE

Background

Plaintiffs Gregor Lesnik and Stjepan Papes moved to compel enforcement of a settlement agreement against Eisenmann Corporation, Eisenmann SE, Eisenmann Anlagenbau Verwaltung GmbH, and Eisenmann Anlagenbau GmbH & Co. KG. The opinion addressed three related motions to file materials under seal: one by the plaintiffs concerning their motion to compel enforcement of the settlement, one by Eisenmann Corporation concerning its opposition, and one by the plaintiffs concerning their reply.

The parties sought redactions in three categories: terms or references to the confidential settlement agreement; names and home addresses of employees of ISM Vuzem d.o.o. and Gregurec; and sensitive business information in Eisenmann Corporation’s purchase order.

Legal standard

The court explained that judicial records generally carry a strong presumption of public access. Because a motion to enforce a settlement is only tangentially related to the underlying claims and is therefore non-dispositive, requests to seal materials connected to that motion were governed by the lower “good cause” standard. That standard requires a particularized showing of specific prejudice or harm from disclosure. The court also noted that sealing requests must be narrowly tailored under Civil Local Rule 79-5.

Ruling

The court denied the request to seal the settlement agreement’s discovery obligations and discussions of those obligations. It reasoned that those obligations were the only settlement terms discussed in the briefing and the court’s related order, so public access was necessary to understand the motion and ruling. The court also found that disclosure would not reveal sensitive or confidential information and rejected the claim that disclosure would subject Eisenmann Corporation to additional litigation.

The court also denied the request to seal the parties’ briefing on the motion to compel enforcement because the only information sought to be sealed in that briefing was the discovery obligations.

The court granted the request to seal the other categories: settlement terms not discussed in the briefing or the court’s order; the names and home addresses of third-party employees of ISM Vuzem d.o.o. and Gregurec; and details of Eisenmann Corporation’s purchase order with Vuzem. It found minimal public interest in those categories and noted that the claims against the defendant had already been dismissed.

Disposition

The court granted in part and denied in part the three motions to seal. It ordered the parties to refile unredacted versions of the briefs and compliant redacted versions of the declarations and exhibits within seven days of the order.