Coventry Capital US LLC v. EEA Life Settlements, Inc.

Background

Defendant EEA Life Settlements, Inc. filed a letter-motion asking the court to keep Exhibit A, identified as ECF No. 384-1, under seal. EEA had attached the exhibit to its opposition to Coventry Capital US LLC’s motion to compel. The exhibit consisted of Coventry’s requests for admission to EEA.

Reasoning

The court recognized a general presumption that court filings should be available to the public, but also considered the privacy interests opposing disclosure. The court stated that documents containing proprietary business information, including internal analyses, business strategies, or customer negotiations, may be kept from public view when disclosure could give competitors an unfair advantage. It also noted that courts regularly protect non-parties’ medical information and that the Southern District of New York’s local rules advise against placing such information in the public file.

The court found that Exhibit A revealed confidential information about EEA’s and Coventry’s negotiations and their respective valuations of EEA’s life-settlement portfolio. It also revealed diagnoses of individuals whose policies were in that portfolio.

Ruling

Judge Sarah L. Cave granted EEA Life Settlements, Inc.’s letter-motion seeking to file Exhibit A under seal. The document at ECF No. 384-1 was ordered to remain visible only to selected parties. The clerk was directed to close ECF No. 383.