Doe v. Roe
- Paul Gardephe
- 1:22-cv-08779
- U.S. District Court · Southern District of New York
- 2
In Doe v. Roe, Judge Gardephe granted Jane Doe’s request to seal a medical-treatment exhibit.
Jane Doe, whose medical-treatment information was kept in a sealed exhibit, and members of the public seeking access to that exhibit.
What happened
In Doe v. Roe, Jane Doe sued John Roe and asked to proceed under a pseudonym and obtain a protective order. She also submitted a letter from her treating therapist as a sealed exhibit.
Doe’s lawyers argued that the letter was relevant to her request but contained highly personal and confidential information about her medical treatment. They asked the court to keep the exhibit from public view under the standards governing access to court records.
Judge Paul G. Gardephe granted the request to seal Exhibit A because it involved information about Doe’s medical treatment.
The detailed version
- Doe v. Roe · No. 1:22-cv-08779
- Paul Gardephe
- Oct. 28, 2022
Background
Jane Doe filed a complaint against John Roe. She then filed a motion asking to proceed under a pseudonym and for a protective order. In connection with that motion, she filed Exhibit A under seal. The exhibit was a letter from her treating therapist.
Request to Seal
Doe’s counsel asked the court to order that Exhibit A remain sealed. Counsel argued that the exhibit was relevant to the relief Doe sought, making it a “judicial document”—a document relevant to the court’s work and useful in the judicial process. Counsel also argued that the exhibit contained highly personal, confidential, and sensitive information about Doe’s medical treatment.
The request cited the general public-access right for judicial documents and the court’s authority to balance that access against privacy interests. It also cited the court’s practice rules, which state that medical records and treatment or diagnosis information may warrant a motion to seal or redact.
Ruling
Judge Paul G. Gardephe granted the request to seal Exhibit A. The court’s order stated that the document involved information pertaining to Doe’s medical treatment.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.