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S.D.N.Y.Procedural orderFiled Apr. 27, 2022

Roche Freedman LLP v. Jason Cyrulnik

Judge
John Koeltl
Docket
1:21-cv-01746
Court
U.S. District Court · Southern District of New York
Pages
3
Civil Procedure
In one sentence

In Roche Freedman v. Cyrulnik, Judge Koeltl granted permission to file specified exhibits and briefing under seal.

Who this affects

The ruling affected the counterclaim defendants and attorneys who sought to seal the filings, as well as public access to the specified exhibits and memorandum of law. The requested sealing concerned client information, fee arrangements, a settlement communication, and the law firm's compensation formula.

What happened

Roche Freedman LLP v. Jason Cyrulnik involved a request by several counterclaim defendants and two attorneys to seal court filings and exhibits. The requested materials included an answer and counterclaims, a memorandum of understanding, a client engagement letter, a firm compensation formula, and a confidential settlement communication.

The request focused on protecting client information, fee arrangements, attorney-client privileged information, and competitive information about the law firm's compensation practices. The requesters argued that disclosure could violate confidentiality obligations and harm the firm's ability to compete for attorneys.

Judge John G. Koeltl granted the application to file the specified materials under seal. The opinion does not provide a separate discussion of the court's reasoning beyond approving the request.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Roche Freedman LLP v. Jason Cyrulnik · No. 1:21-cv-01746
Judge
John Koeltl
Date
Apr. 27, 2022

Background

Counterclaim defendants Kyle Roche, Devin Freedman, Nathan Holcomb, Edward Normand, and Amos Friedland, identified in the request as the firm partners, asked for permission to file Exhibits 1, 2, and 4 to Sean Hecker's declaration under seal. Roche and Freedman also asked to file under seal their memorandum supporting a motion to dismiss. The application was filed in Roche Freedman LLP v. Jason Cyrulnik.

Exhibit 1 was Cyrulnik's corrected answer to the amended complaint and his counterclaims. Exhibit 2 was a memorandum of understanding and two related exhibits, including a client engagement letter and the law firm's attorney-compensation formula. Exhibit 4 was described as a confidential settlement communication.

Arguments for Sealing

The applicants argued that portions of the materials contained information about specific clients and their fee arrangements. They relied on the presumption of public access to court records and the exception allowing sealing when necessary to protect more important interests. They argued that attorney-client privilege and confidentiality obligations justified sealing the client-related information. The request stated that, under Florida law, client identity and fee-payment information can be protected by attorney-client privilege, and that attorneys have duties to keep client information confidential.

The applicants separately argued that the firm's compensation formula should be sealed because public disclosure could harm its competitive position. They asserted that disclosure would help other law firms compete with Roche Freedman LLP when recruiting attorneys.

Ruling

The court's order states, "Application Granted," and is marked "SO ORDERED" by Judge John G. Koeltl. The court therefore granted the application for permission to file the specified exhibits and memorandum of law under seal. The text provided does not include a longer explanation or separately describe the precise sealing limits beyond the requests summarized in the letter.

The authoritative version

Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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