Guidehouse LLP v. Shah
- Vyskocil
- 1:19-cv-09470
- U.S. District Court · Southern District of New York
- 2
In Guidehouse v. Shah, Judge Vyskocil granted Guidehouse’s request to redact and seal three exhibits.
Guidehouse LLP, Rizwan Shah, and non-party PricewaterhouseCoopers LLP; the ruling concerns public access to three exhibits and the confidentiality of information in them.
What happened
In Guidehouse LLP v. Shah, Guidehouse asked the court to allow redactions in publicly filed copies of three exhibits and to keep unredacted copies under seal. Defendant Rizwan Shah consented to the request.
The exhibits were agreements concerning Shah’s employment, Guidehouse’s business structure and Shah’s equity interests, and Shah’s withdrawal from PricewaterhouseCoopers LLP. Guidehouse stated that the documents contained confidential, private, and competitively valuable information, including personal financial information.
Judge Mary Kay Vyskocil granted the request. The court allowed the public copies of Exhibits A, B, and C to be redacted and ordered that unredacted versions be maintained under seal, while noting that evidence admitted at trial would become part of the public record.
The detailed version
- Guidehouse LLP v. Shah · No. 1:19-cv-09470
- Vyskocil
- June 14, 2021
Background
Guidehouse asked the court to permit redactions in the publicly filed copies of Exhibits A, B, and C to a declaration supporting its motions in limine, which are motions addressing evidence before trial. It also asked to file unredacted versions of those exhibits under seal, meaning they would not be available in the public court file. Shah consented to the request.
The exhibits were described as follows:
- Exhibit A was Shah’s employment agreement with Guidehouse, containing confidential information about his employment terms. - Exhibit B was the operating agreement for Guidehouse’s holding company, containing confidential and proprietary information about the company’s structure and the terms governing Shah’s equity interests. - Exhibit C was Shah’s special retention bonus agreement with his former firm, PricewaterhouseCoopers LLP, containing confidential information about the terms of his withdrawal from that partnership.
Guidehouse stated that the exhibits contained information with competitive value to Guidehouse and, for Exhibit C, to PricewaterhouseCoopers LLP. It also stated that disclosure could harm those businesses. The request further identified Shah’s privacy interest in keeping his personal financial information confidential.
Court’s Analysis
The opinion stated that court documents generally carry a presumption of public access, but that presumption may be outweighed by countervailing considerations, including the privacy interests of people resisting disclosure. It concluded that the privacy interests of Guidehouse, Shah, and non-party PricewaterhouseCoopers LLP justified redacting portions of the public filings.
Ruling
The court granted Guidehouse’s request to redact the publicly filed copies of Exhibits A, B, and C and to maintain unredacted versions under seal. Judge Mary Kay Vyskocil stated that any evidence admitted at trial would be part of the public record and could not remain sealed. The court also requested that the Clerk of Court terminate the motion at docket entry 61.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.