G&G Closed Circuit Events, LLC v. Sanchez Torres
- Ronnie Abrams
- 1:20-cv-03487
- U.S. District Court · Southern District of New York
- 2
In G&G Closed Circuit Events v. Sanchez Torres, Judge Abrams ordered G&G to justify its redactions or file unredacted exhibits.
G&G Closed Circuit Events, LLC, whose redacted exhibits were addressed by the order; the public access to those court filings was also implicated.
What happened
In G&G Closed Circuit Events, LLC v. Sanchez Torres, G&G attached a redacted exhibit to its complaint and similar redacted exhibits to affidavits supporting its pending motion for default judgment. It had not asked the court for permission to redact those public filings.
The court explained that its rules require a party seeking to redact a filing to submit a public letter motion explaining the request, file the proposed-redacted version publicly, and file an unredacted version under seal. Any redaction must be narrowly tailored and consistent with the presumption that judicial documents should be publicly accessible.
Judge Ronnie Abrams ordered G&G, by January 1, 2021, either to file the required letter motion or to file unredacted copies of the exhibits. The order addressed the filing of redacted documents and did not decide the pending motion for default judgment.
The detailed version
- G&G Closed Circuit Events, LLC v. Sanchez Torres · No. 1:20-cv-03487
- Ronnie Abrams
- Dec. 11, 2020
Background
G&G Closed Circuit Events, LLC filed a complaint with an exhibit in redacted form. It later filed affidavits by Nicolas J. Gagliardi and Joseph P. Loughlin in support of its pending motion for default judgment, and those affidavits also included a redacted exhibit. The court stated that G&G had not sought permission to redact the public filings.
Court’s Rules and Analysis
Judge Abrams referred to the court’s Individual Rules and Practices in Civil Cases. Under those rules, a party seeking to file a redacted document must electronically file a public letter motion requesting permission. The letter must explain the reasons for the proposed redactions and must not include confidential information. The party must also publicly file a version showing the proposed redactions and file an unredacted version under seal with the proposed redactions highlighted.
The court stated that redaction or sealing of a court filing must be narrowly tailored to serve the purpose supporting it and must be consistent with the presumption in favor of public access to judicial documents.
Order
The court ordered G&G, no later than January 1, 2021, to do one of two things: file a letter motion complying with the court’s requirements or file unredacted copies of the exhibits on the docket. This order concerned the redacted filings; the text does not state a disposition of G&G’s pending motion for default judgment.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.