Richmond v. Montefiore Medical Center

Background

Montefiore Medical Center submitted a sealed letter seeking a pre-motion conference about a proposed motion for summary judgment. It also filed a public version with two sentences redacted and asked that those sentences remain sealed. Lynn Richmond sought the same relief.

The redacted sentences concerned notes. The court stated that the first sentence did not disclose the notes’ contents, so the reason for that redaction was unclear. The court also noted that Richmond seeks damages for emotional distress and has therefore placed her mental state at issue. It further stated that the notes relate to the merits of Montefiore’s anticipated summary-judgment motion.

Richmond separately submitted a sealed letter requesting a pre-motion conference about a proposed motion for partial summary judgment. Her public version contained three redacted passages referring to or quoting documents Montefiore had designated confidential under a protective order. Richmond stated that she took no position on whether those passages should remain sealed, and Montefiore had not asked to keep them sealed.

Rulings

The court required the parties to file supplemental letters by December 12, 2022, addressing why Richmond’s privacy interest outweighed the public’s presumptive right of access to judicial documents. The opinion did not finally resolve that sealing request.

Because neither party requested that the three redacted passages in Richmond’s letter remain sealed, the court ordered the unredacted version at Docket No. 63 unsealed. It directed the Clerk of Court to change that docket entry’s viewing level to public. The court also directed the Clerk to terminate Docket No. 61 as moot.

Classification

This was a procedural order addressing access to sealed court filings and related docket administration. It did not decide either party’s proposed summary-judgment motion.