In re Lifetrade Litigation
- James Oetken
- 1:17-cv-02987
- U.S. District Court · Southern District of New York
- 1
In re Lifetrade Litigation: Judge Parker sealed a rough deposition transcript draft over Wells Fargo’s objection to public filing.
Wells Fargo and the public’s access to Exhibit A to ECF No. 1070, a rough draft of a deposition transcript.
What happened
In In re Lifetrade Litigation, Wells Fargo objected to publicly filing an exhibit because it was a rough deposition-transcript draft that Wells Fargo had not reviewed for confidential information or signed.
The court found that sealing the exhibit was proper because the document was an unreviewed draft and the public’s interest in access was lower than the parties’ interest in reviewing it before disclosure.
Judge Parker ordered the clerk to seal Exhibit A to ECF No. 1070, filed as ECF No. 1070-1.
The detailed version
- In re Lifetrade Litigation · No. 1:17-cv-02987
- James Oetken
- June 7, 2023
Background
Wells Fargo Defendant objected to the public filing of Exhibit A to ECF No. 1070. The exhibit was a rough draft of a deposition transcript that Wells Fargo had not yet had an opportunity to review for confidentiality designations or sign.
Court’s analysis
The court determined that sealing the exhibit was proper under the standard described in Lugosch v. Pyramid Co. of Onondaga. It concluded that, given the document’s status as a rough draft and the contents of the letter motion, the public presumption of access was lower than the parties’ interest in reviewing the deposition transcript before public disclosure.
Order
The court directed the clerk to seal the exhibit at ECF No. 1070-1. The opinion was signed by Katharine H. Parker, United States Magistrate Judge.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.