Dumontet v. UBS Financial Services, Inc.

Background

Christian Dumontet moved under the court’s electronic filing rules to keep four documents—ECF Nos. 51, 52-15, 52-17, and 45-5—sealed and to replace them on the public docket with redacted versions. The proposed redactions covered Dumontet’s personal financial information: his net worth, liquid assets, and annual income. The defendants did not oppose the motion.

Legal standard

The court applied the Second Circuit’s three-step framework for sealing court records. First, it determined whether the documents were “judicial documents,” meaning documents submitted to the court that are relevant to the court’s work and useful in the judicial process. Second, it assessed the strength of the public-access presumption. Third, it balanced that presumption against factors favoring nondisclosure, including privacy interests.

Ruling

The court found that the documents were judicial documents but that the presumption of public access was low because the limited personal financial information was unlikely to have significance in the court’s consideration of the pending motion to dismiss. It concluded that Dumontet’s privacy interests outweighed the public interest in disclosure of the redacted information at that stage of the case and on the record before it.

The court granted the motion to seal with respect to the specified redactions. It directed the Clerk of Court to restrict viewing of the identified docket entries to the court and the parties and to terminate the motion pending at Docket No. 57.