Care Ambulance Service, Inc. v. Scott Griffith Collaborative Solutions, LLC
- Saundra Armstrong
- 4:19-cv-08171
- U.S. District Court · Northern District of California
- 5
Scott Griffith Collaborative Solutions v. Falck Northern California, Judge C. Spero granted in part and denied in part one sealing motion and denied two others.
SGCS and Falck must publicly file the documents covered by the denied requests and the portions not approved for sealing. Nonparty AMR and nonparty Robert Garrett were affected because their confidentiality designations did not, by themselves, justify sealing.
What happened
In Scott Griffith Collaborative Solutions, LLC v. Falck Northern California Corp., and the related case involving Falck USA, Inc., the parties asked to keep documents connected to Falck’s sanctions motion from public view. The documents included briefs, deposition transcripts, and other exhibits.
The court applied a demanding standard because the sanctions motion could have ended SGCS’s claims. It allowed sealing only for the specific passages identified in Falck’s July 9 motion and rejected requests that were not supported with enough detail or declarations.
Judge C. Spero granted in part and denied in part Falck’s July 9, 2021 motion, denied SGCS’s sealing motion, and denied Falck’s July 30, 2021 motion. The parties were ordered to file the remaining documents publicly between October 5 and October 12, 2021, subject to a possible renewed motion concerning two deposition pages.
The detailed version
- Care Ambulance Service, Inc. v. Scott Griffith Collaborative Solutions, LLC · No. 4:19-cv-08171
- Saundra Armstrong
- Sept. 30, 2021
Background
Scott Griffith Collaborative Solutions, LLC (SGCS) and Falck USA, Inc., together with related entities referred to collectively as Falck, filed administrative motions asking the court to keep documents under seal. The motions concerned materials submitted in connection with Falck’s motion for sanctions. The order used the docket numbers from Case No. 19-cv-06104-SBA but stated that it applied equally to substantially identical filings in Case No. 19-cv-08171-SBA.
Legal standard
The court stated that filings are presumptively public. Because the documents were connected to a sanctions motion that could have resulted in the termination of SGCS’s claims, the court applied the “compelling reasons” standard. The court also required requests to be narrowly tailored to only the material that could properly be sealed. When a party sought sealing based on another party’s or a nonparty’s confidentiality designation, the designating party had to submit a declaration explaining the reasons for sealing within four days.
Falck’s July 9, 2021 motion
Falck’s motion relied solely on confidentiality designations by SGCS and nonparty AMR. SGCS submitted a declaration supporting sealing portions of the materials, but AMR did not submit a responsive declaration. The court granted the motion only as to the specifically listed portions of Falck’s sanctions motion, Coffin’s deposition transcript and duplicate copies, LeSage’s deposition transcript and duplicate copies, Lenn’s deposition transcript and duplicate copies, Garrett’s deposition transcript and duplicate copies, and certain exhibits. The listed material included particular dollar amounts, locations, names, numbers, percentages, and specified passages.
The court denied the July 9 motion as to all material not specifically addressed in the order. Falck was directed to file public unredacted versions of documents not partially sealed and public redacted versions of documents sealed only in part, no earlier than October 5 and no later than October 12, 2021. The court noted that SGCS could file a new motion specifically identifying other exhibits containing page 129 of Coffin’s deposition or page 164 of LeSage’s deposition if SGCS believed those pages warranted sealing.
SGCS’s sealing motion
SGCS sought to seal portions of its opposition brief and related documents based solely on confidentiality designations by AMR and nonparty Robert Garrett. Neither AMR nor Garrett filed a responsive declaration explaining why the documents should remain sealed. The court therefore denied SGCS’s motion and ordered SGCS to file the documents unredacted during the October 5–12 filing period.
Falck’s July 30, 2021 motion
Falck also sought to seal portions of its reply brief based on confidentiality designations by SGCS and AMR. The supporting declaration described the material only as portions of the reply that cited, quoted, or summarized unspecified material. Because neither SGCS nor AMR filed a responsive declaration and the request did not adequately identify the material, the court denied this motion. Falck was ordered to file the reply brief unredacted during the October 5–12 filing period.
Disposition
The court granted in part and denied in part Falck’s July 9, 2021 sealing motion. It denied SGCS’s sealing motion and denied Falck’s July 30, 2021 sealing motion. The order required the parties to make the documents public as specified, while stating that Falck should not file documents containing the identified Coffin or LeSage deposition pages until the court resolved any renewed sealing motion concerning them.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.