Naula Ndugga v. Bloomberg L.P.
- Gregory Woods
- 1:20-cv-07464
- U.S. District Court · Southern District of New York
- 1
In Naula Ndugga v. Bloomberg L.P., Magistrate Judge Gorenstein granted motions to seal materials containing confidential business and personal information.
The ruling affects Naula Ndugga, Bloomberg L.P. and the other parties to the case, and third-party employees or individuals whose performance, compensation, or personal information appears in the sealed materials.
What happened
Naula Ndugga v. Bloomberg L.P. involved requests to seal letters and exhibits that the defendant had designated as confidential under a protective order. The materials concerned performance ratings and compensation for third-party employees.
The documents had been filed in redacted form. The defendant said they contained confidential business information that it does not disclose to non-supervisory employees, as well as personal information about individuals.
Magistrate Judge Gabriel W. Gorenstein said discovery disputes receive a low presumption of public access and granted the motions to file certain portions under seal.
The detailed version
- Naula Ndugga v. Bloomberg L.P. · No. 1:20-cv-07464
- Gregory Woods
- July 7, 2023
Background
The parties moved to seal letters filed at Docket Numbers 202 and 206 and the exhibits attached to them. The materials had been designated confidential by the defendant under the case's protective order. Redacted versions were filed at Docket Numbers 201 and 203.
Reasons for Sealing
The defendant stated that the documents contained candid discussions about numerical performance ratings and compensation for various third-party employees. It also stated that the documents included suggested numerical performance ratings that it does not disclose to non-supervisory employees and treats as confidential business information. The opinion also notes that some exhibits and redactions involved individuals' privacy concerns.
Ruling
The court conducted the required balancing analysis concerning public access to court records. It found that materials relating to discovery disputes receive a low presumption of public access and that the documents involved confidential business information or individual privacy concerns. Magistrate Judge Gorenstein granted the motions to file certain portions of the documents under seal, Docket Numbers 200 and 204.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.