Iacovacci v. Brevet Holdings, LLC
- Figueredo
- 1:18-cv-08048
- U.S. District Court · Southern District of New York
- 3
In Iacovacci v. Brevet Holdings, Judge Figueredo granted Iacovacci’s request to seal a tax return and redact deposition testimony.
Paul Iacovacci, his wife, and third party Enascor, LLC; the public’s access to the specified court materials was limited.
What happened
In Iacovacci v. Brevet Holdings, LLC, Paul Iacovacci asked the court to seal his 2015 joint tax return with his wife and redact limited portions of his October 2021 deposition. The request was unopposed.
The court found that the tax return contained sensitive personal and financial information. It also found that the deposition excerpts contained competitively sensitive profit-and-loss information about Enascor, LLC, a third party, and that disclosure could cause competitive harm.
Judge Valerie Figueredo granted the letter motion to seal and redact. The court directed the Clerk of Court to terminate the motion.
The detailed version
- Iacovacci v. Brevet Holdings, LLC · No. 1:18-cv-08048
- Figueredo
- June 1, 2023
Background
Paul Iacovacci submitted a letter motion asking the court to seal two categories of materials filed in connection with the parties’ summary-judgment motions:
- his 2015 personal joint tax return with his wife; and - portions of his October 2021 deposition, with limited redactions.
The opinion states that the motion was unopposed.
Reasoning
The court concluded that sealing the tax return was warranted because it contained sensitive personal and financial information about Iacovacci and his family. The court noted that courts routinely protect tax returns from public disclosure.
The court also concluded that the proposed deposition redactions were warranted. The relevant testimony contained sensitive, recent profit-and-loss information about Enascor, LLC, a third party. The court accepted the assertion that disclosure would likely cause competitive harm and noted that Enascor’s privacy interests supported sealing the information. The court applied the standard described by the U.S. Court of Appeals for the Second Circuit in Lugosch v. Pyramid Co.
Ruling
The court granted Iacovacci’s letter motion to seal the 2015 tax return and to file the deposition transcript with limited redactions. It directed the Clerk of Court to terminate the motion at ECF No. 350.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.