Joffe v. King & Spalding LLP

Background David A. Joffe, the plaintiff and a self-represented party, asked for permission to file Exhibit 1 to his opposition to King & Spalding LLP’s Motion in Limine No. 9. The exhibit was a copy of Joffe’s October 25, 2018 letter to a former client in an unrelated matter. The letter had already been redacted in discovery to protect attorney-client communications.

Requested Redactions Joffe also sought to redact nonprivileged confidential information identifying the former client and entities involved in the former client’s dispute. He argued that public disclosure would affect innocent third parties’ privacy interests and involve sensitive communications connected to business relationships with nonparties. He stated that the proposed redactions were narrowly limited to names, entities, places, unique job titles, and other personal details that could disclose a person’s or entity’s identity.

Parties’ Positions Joffe’s letter-motion stated that the defendant opposed the filing with the requested redactions. Later that day, King & Spalding’s attorney notified the court that this was a typographical error and that the defendant had no objection to the proposed redactions. Joffe confirmed the error and offered to file a corrected letter-motion if requested.

Ruling Judge Valerie E. Caproni stated that, in light of the parties’ later statements that there was no dispute about the redactions, the request was GRANTED. The order therefore permitted the requested redactions to the letter. The opinion text does not provide a separate analysis beyond noting the absence of a dispute.