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S.D.N.Y.Procedural orderFiled Feb. 1, 2021

Rosa M. v. Bank of Nova Scotia

Judge
Valerie Caproni
Docket
1:14-cv-01459
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedureDiscovery
In one sentence

In Rosa M. v. Bank of Nova Scotia, Judge Caproni ordered plaintiffs to state whether they object to publicly filing unredacted materials.

Who this affects

The plaintiffs and defendants in the litigation, because the order governed whether confidential portions of the defendants’ court filings would remain sealed or become publicly available.

What happened

In Rosa M. v. Bank of Nova Scotia, defendants asked the court to keep redacted portions of a legal memorandum and exhibits under seal. The materials had been designated confidential under a protective order.

The court directed plaintiffs to say by February 12, 2021, whether they objected to filing unredacted versions publicly. If they objected, they had to explain why the redactions were justified and could propose narrower redactions. The order did not expressly grant or deny the defendants’ request to seal.

Judge Valerie E. Caproni also allowed defendants to respond by February 19, 2021, if they wished. The order emphasized the public’s presumptive right to access court filings.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Rosa M. v. Bank of Nova Scotia · No. 1:14-cv-01459
Judge
Valerie Caproni
Date
Feb. 1, 2021

Background

The defendants—including The Bank of Nova Scotia, Barclays Bank PLC, Société Générale, and The London Gold Market Fixing Limited—asked the court to seal redacted portions of their January 29, 2021 memorandum supporting a motion to take depositions of Rosa M. Abrantes-Metz and Gustavo Bamberger, along with exhibits B through E.

The request relied on a January 18, 2017 protective order. That order provided that confidential or highly confidential discovery materials filed with the court, and filings that disclosed those materials, would be filed under seal until the court issued a further order. The materials attached to the memorandum had been designated confidential by plaintiffs and previously filed under seal.

Court’s directives

The court ordered plaintiffs to inform it by February 12, 2021, whether they objected to filing unredacted versions of the memorandum and exhibits at docket entry 509 on the public docket. If plaintiffs objected, they had to explain why the proposed redactions were justified despite the presumption of public access to court records recognized in Lugosch v. Pyramid Co. of Onondaga. The court also said plaintiffs could propose narrower redactions, but would have to show that those redactions overcame the presumption of access.

The court encouraged the parties to consult its earlier endorsements at docket entries 480 and 494. It allowed defendants to reply to plaintiffs’ letter by February 19, 2021, if defendants chose to do so.

Disposition

Judge Valerie E. Caproni entered the directives and marked the matter “SO ORDERED.” The opinion text does not expressly state that the court granted or denied the defendants’ sealing request; instead, it required plaintiffs to state their position and set deadlines for any further submissions.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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