Robinson v. De Niro
- Lewis Liman
- 1:19-cv-09156
- U.S. District Court · Southern District of New York
- 2
In Robinson v. De Niro, Judge Parker granted Robinson’s request to publicly file three exhibits with phone numbers and certain names redacted.
Graham Chase Robinson, the defendants, the public, and non-Canal employees whose names and phone numbers appeared in the text messages were affected. The approved filing allowed public access to the exhibits while permitting the specified personal information to remain redacted.
What happened
In Robinson v. De Niro and Canal Productions, Inc., Graham Chase Robinson asked to publicly file three exhibits supporting her request to compel documents that defendants withheld as privileged. The exhibits contained text messages, and Robinson sought to redact phone numbers and the names of non-Canal employees.
Robinson argued that limited redactions would protect privacy while allowing the public to understand the texts and the issues before the court. She opposed completely sealing the exhibits. Defendants opposed filing the documents with only those limited redactions.
The application was granted. The filing does not provide a separate explanation of the court’s ruling beyond that approval. The application was marked granted by Magistrate Judge Katharine H. Parker.
The detailed version
- Robinson v. De Niro · No. 1:19-cv-09156
- Lewis Liman
- Mar. 9, 2022
Background
Graham Chase Robinson refiled a request for permission to publicly file, in redacted form, three exhibits supporting her motion to compel production of documents withheld by defendants on privilege grounds. The exhibits consisted of text-message conversations involving Canal Productions, Inc. employees and other participants.
Requested Redactions
Robinson asked to redact all phone numbers and the names of non-Canal employees who participated in the text exchanges. She argued that these narrow redactions would protect personal privacy while preserving public access to the substance of the texts. She also argued that completely sealing the exhibits was unwarranted because the documents concerned issues before the court.
The letter states that defendants had originally labeled the text messages confidential and opposed public filing with only limited redactions. Robinson’s letter also presented her arguments concerning the crime-fraud exception to attorney-client privilege, including her contention that the messages supported her position in the motion to compel. Those arguments were Robinson’s stated position; the provided text does not show a merits ruling on the privilege dispute.
Ruling
The filing is marked “APPLICATION GRANTED” by Magistrate Judge Katharine H. Parker. Based on the provided text, the court granted Robinson’s request to file the three exhibits publicly with the proposed limited redactions. The text does not provide a separate written explanation of the court’s reasoning or separately state the treatment of the underlying motion to compel.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.