eCardless Bancorp, Ltd. v. PayPal Holdings, Inc.
- Beth Freeman
- 5:24-cv-01054
- U.S. District Court · Northern District of California
- 3
eCardless Bancorp v. PayPal Inc.: Judge Freeman granted in part and denied in part a motion to seal selected exhibit portions.
eCardless Bancorp, Ltd., which must file revised versions of the filing and exhibits; PayPal Inc.; and members of the public seeking access to the court records.
What happened
In eCardless Bancorp, Ltd. v. PayPal Inc., the plaintiff asked to seal selected portions of two exhibits attached to its filing. It argued that one exhibit was covered by an earlier sealing order and that portions of the other contained information only marginally related to the dispute.
The court denied sealing for the first exhibit because the earlier order was not sealed and the plaintiff provided no legal basis for its argument. The court granted sealing for specified names, financial percentages, and personal addresses in the second exhibit because the information was personal in nature. The plaintiff must file unredacted versions of the filing and exhibits with only the approved redactions by May 23, 2024.
Judge Beth Labson Freeman issued the order, granting in part and denying in part the administrative motion to file under seal.
The detailed version
- eCardless Bancorp, Ltd. v. PayPal Holdings, Inc. · No. 5:24-cv-01054
- Beth Freeman
- May 10, 2024
Background
Plaintiff eCardless Bancorp, Ltd. filed an amended administrative motion to seal selected portions of two exhibits attached to its filing. For the first exhibit, an order concerning a discovery dispute, eCardless argued that the order had been sealed by the court that previously handled the litigation and should remain sealed out of respect for that court's order. For the second exhibit, a will, eCardless sought to seal individual names, financial percentages, and the names and personal addresses of two witnesses. It argued that the will was, at most, only marginally related to the issues in the litigation and that the proposed redactions were narrowly limited.
Legal standard
The court explained that judicial records generally carry a strong presumption of public access. For records more than marginally related to the underlying claims, a party must show compelling reasons to overcome that presumption. For records unrelated or only marginally related to the merits, the party must instead show good cause under Federal Rule of Civil Procedure 26(c), including a specific showing of harm or prejudice from disclosure. Broad, unsupported allegations of harm are insufficient.
Ruling
The court found good cause to seal certain portions of the will but not the first exhibit. It denied sealing the first exhibit because eCardless provided no legal basis for its argument and, contrary to eCardless's representation, the earlier order was not sealed. The court granted sealing for the individual names and financial percentages on specified pages of the will and the names and personal addresses of two witnesses who signed it, finding that this information was personal in nature. The court stated that it could revisit that ruling later.
The administrative motion was GRANTED IN PART AND DENIED IN PART. The court ordered eCardless to file an unredacted version of the filing and its corresponding exhibits, with redactions limited to those approved in the order, no later than May 23, 2024.
Effect
The order concerns access to particular court filings and exhibits. It does not decide the underlying claims in the litigation.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.