Manbro Energy Corporation v. Chatterjee Advisors, LLC
- Lorna Schofield
- 1:20-cv-03773
- U.S. District Court · Southern District of New York
- 2
In Manbro Energy v. Chatterjee Advisors, Judge Schofield granted defendants’ sealing application and ordered documents sealed or redacted.
The order affects Manbro Energy Corporation, Chatterjee Advisors, LLC and the other defendants, the non-parties whose confidential or personal information appears in the materials, Haldia Petrochemicals Ltd., and public access to the identified court filings.
What happened
In Manbro Energy Corporation v. Chatterjee Advisors, LLC, defendants responded to Manbro’s request to seal or redact a motion and exhibits. Defendants agreed that some exhibits could be filed publicly, asked to redact others, and asked that several remain sealed entirely.
Defendants said the materials contained confidential information about non-party investors, Haldia Petrochemicals Ltd., valuations, personal contact information, internal discussions, negotiations, and business documents. They argued that the public-access interest was relatively weak because much of the information was not relevant to the court’s work.
Judge Lorna G. Schofield granted the application for substantially the stated reasons. She directed defendants to file by January 13, 2023, a letter attaching unredacted versions of exhibits they agreed could be filed entirely in public, and directed the Clerk to keep under seal all documents previously filed under seal.
The detailed version
- Manbro Energy Corporation v. Chatterjee Advisors, LLC · No. 1:20-cv-03773
- Lorna Schofield
- Jan. 9, 2023
Background
The court considered defendants’ response to Manbro’s request to file under seal Exhibits A–J, L–P, R–T, W, and X to a declaration supporting Manbro’s motions in limine, along with Manbro’s Motion in Limine No. 7. Defendants did not oppose public filing of Exhibits B, D, F–H, J, L, S, and X. They requested redactions to the motion and Exhibits A, C, I, and P, and requested that Exhibits E, O, R, T, and W remain sealed in their entirety.
Reasons Given for Sealing
Defendants stated that the materials contained or referred to non-public, confidential, proprietary, financial, or commercially sensitive information. The identified information included details about non-party investors, valuations of non-party Haldia Petrochemicals Ltd., personal contact information for non-parties, internal deliberations and negotiations with non-parties, and Haldia’s business documents. Defendants relied on the common-law presumption of public access to judicial documents and the principle that this presumption must be balanced against privacy and confidentiality interests. They also stated that redaction would sometimes be impracticable or would leave documents unintelligible. The letter noted that the court had previously granted sealing requests involving similar information.
Ruling
Judge Lorna G. Schofield granted the application for substantially the reasons stated in defendants’ letter. By January 13, 2023, defendants were required to file a letter attaching unredacted versions of each discussed exhibit that they agreed could be filed entirely on the public docket. The Clerk of Court was directed to maintain under seal all documents filed under seal to date. The order did not otherwise describe separate dispositions for each exhibit beyond these directives.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.