Teachers Insurance & Annuity Association of America v. Malafa

Background

Teachers Insurance & Annuity Association of America (TIAA), represented by counsel, asked the court for permission to file two exhibits under seal. The exhibits were submitted in connection with TIAA’s proposed order to show cause seeking a preliminary injunction and temporary restraining order.

One exhibit was an email from a TIAA client to defendant Malafa’s former TIAA email address. The other was an email from Malafa to another TIAA client. TIAA requested that the unredacted exhibits be filed under seal to protect its clients’ private information and said that redacted versions would be filed publicly.

TIAA’s letter discussed the general presumption that judicial documents are publicly accessible and argued that the clients’ information was private and constituted a trade secret. Those points were presented by TIAA in support of its application.

Ruling

Judge Valerie Caproni endorsed the application with the statement, “Application GRANTED. SO ORDERED.” The opinion text does not include further explanation of the court’s reasoning or separately state findings about whether the information was a trade secret.

Effect

The order granted TIAA permission to file the two exhibits under seal. It did not, in the text provided, decide the proposed request for a preliminary injunction or temporary restraining order.