Paravas v. Long Tran
- Alison Nathan
- 1:21-cv-00807
- U.S. District Court · Southern District of New York
- 4
In Paravas v. Long Tran, Judge Parker denied Paravas’s request to delete sealed medical records from the court file.
Trisha Paravas’s sealed medical records remain in the court file, while the public remains unable to access them absent court permission. Long Tran’s potential future access would be addressed through court procedures.
What happened
In Paravas v. Long Tran, Trisha Paravas asked the court to permanently delete medical records she had submitted in support of her request for emotional-distress damages. The records had been filed under seal, and Long Tran did not respond.
The court said the records were part of the official court file because they supported Paravas’s damages request and were considered in deciding the amount of damages. The court also said the records would remain inaccessible to the public because they were sealed, and that future concerns about Tran’s access could be addressed with a protective order.
Judge Katharine H. Parker denied Paravas’s request to remove or strike the records and ordered that they remain under seal.
The detailed version
- Paravas v. Long Tran · No. 1:21-cv-00807
- Alison Nathan
- Mar. 11, 2022
Background
After Long Tran’s default, the court held a hearing to determine whether Trisha Paravas should receive damages and, if so, how much. Paravas testified that Tran’s defamation caused emotional distress, including sleeplessness, hives, and hair loss. She submitted medical records supporting that testimony and asked the court to file them under seal. The court granted that sealing request.
Judge Alison J. Nathan later adopted the recommendation that Paravas receive $5,000 in emotional-distress damages. Paravas then filed a document asking the court to permanently delete the medical records. She argued that the records were irrelevant because emotional-distress damages had largely been rejected, that keeping them violated her privacy, and that the public or Tran might misuse them. The court treated her filing as a motion to remove or strike the records from the court file.
Court’s Reasoning
The court explained that documents submitted to support a motion are generally “judicial documents” when they are relevant to the court’s work and useful in deciding the case. Such documents are ordinarily available to the public, although courts may seal them when privacy or other countervailing interests justify doing so.
The court rejected Paravas’s argument that the records were irrelevant. She had submitted them in support of her request for damages, and the court had relied on them in determining the appropriate damages award. Because the records were under seal, the public could not access them. The court also stated that Paravas would receive notice and an opportunity to object if someone later sought permission to access them.
The court further explained that, because Paravas had placed her medical conditions at issue by seeking emotional-distress damages, Tran would have been entitled to seek the records through discovery if he had appeared and challenged her allegations. The complete record would also be needed if Tran later sought to challenge the judgment. The court found no legal basis for removing the records from the file.
Ruling
Judge Katharine H. Parker denied Paravas’s motion to strike or remove the medical records. The records were to remain under seal. The opinion does not state that the court changed or vacated the previously adopted damages award.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.