Rinaldi v. SCA La Goutte, D'Or

Background

Defendants SCA La Goutte D’Or and SAS Ch. & A. Prieur filed a letter motion asking the court to seal 21 pages submitted with the motion and a declaration that would be filed later. The materials concerned the defendants’ request for a witness to testify remotely from France at trial. The defendants also asked to redact references to the materials in a public supplemental submission.

The defendants represented that the materials contained confidential personal information obtained from personal documents provided to counsel by one of their witnesses. They stated that the information was not known to the public, did not concern public health or safety, did not involve a public entity or official, and was not central to the matters before the court. The opinion states that plaintiff’s counsel had not responded to the defendants’ request for the plaintiff’s position, although the parties had previously agreed to redactions concerning similar confidential information.

Court’s analysis

The court applied the framework governing access to judicial documents. It considered whether the materials were judicial documents, the weight of the public-access presumption, and competing considerations such as privacy interests. The court noted that the presumption of public access is generally lower for materials connected to non-dispositive motions than for materials introduced at trial or submitted with motions that could resolve claims.

The court concluded that the public interest in the materials was minimal because they did not concern public health or safety, a public entity or official, or the core matters before the court. In contrast, protecting confidential personal information and the witness’s privacy supported sealing. The court also found that the requested sealing was narrowly tailored to protect personal information and prevent unauthorized dissemination of data covered by the European Union’s General Data Protection Regulation.

Ruling

Judge Vernon S. Broderick granted the application. The order directed that the documents filed with the letter motion be kept under seal, allowed the later-filed declaration to be submitted under seal, and allowed the supplemental submission to include appropriate redactions based on those materials.