Crespo v. Kramer Levin Naftalis & Frankel LLP
- Valerie Caproni
- 1:23-cv-07304
- U.S. District Court · Southern District of New York
- 2
In Crespo v. Kramer Levin, Judge Caproni granted redactions and limited public access to personal contact information in the complaint.
Yajaira V. Crespo, Kramer Levin Naftalis & Frankel LLP, and the firm’s employees and former employees whose personal contact information appeared in the attachment.
What happened
In Crespo v. Kramer Levin Naftalis & Frankel LLP, the defendant asked the court to redact four personal cell phone numbers and one personal email address from an attachment to Yajaira V. Crespo’s complaint. Crespo filed the action without a lawyer and did not consent to the request.
The defendant said the information belonged to its employees and former employees, who were not parties to the case, and was unrelated to Crespo’s claims. The court considered the defendant’s letter motion and Crespo’s response.
Judge Valerie Caproni granted the request. She directed the Clerk to restrict access to the original complaint filing to the court and the parties, and said the court would re-file the complaint for Crespo with the phone numbers and email address redacted.
The detailed version
- Crespo v. Kramer Levin Naftalis & Frankel LLP · No. 1:23-cv-07304
- Valerie Caproni
- Oct. 10, 2023
Background
Kramer Levin Naftalis & Frankel LLP filed a letter motion asking the court to remove the complaint and attachments from public access and re-file them with limited redactions. The requested redactions covered four personal cell phone numbers and one personal email address appearing in an attachment that listed five of the firm’s employees and former employees. The defendant stated that it contacted Yajaira V. Crespo, who filed the case without a lawyer, but that she refused to consent.
Legal standard
The defendant relied on the rule governing privacy protections in court filings and on Lugosch v. Pyramid Co. of Onondaga. Under that framework, courts weigh the public’s presumptive right to access judicial documents against competing interests, including the privacy interests of people whose information appears in the filing. The defendant argued that the requested redactions were narrowly limited and that the contact information was not relevant to Crespo’s claims.
Ruling
After considering the defendant’s letter motion, docket entry 9, and Crespo’s response, docket entry 10, Judge Valerie Caproni found that the privacy interests of the non-parties listed in the complaint outweighed the presumption of public access. The court granted the application. It directed the Clerk of Court to restrict docket entry 1 to access by the court and the parties, and stated that the court would re-file the complaint on Crespo’s behalf with the phone numbers and email address on page 12 redacted.
Effect of the order
This order addressed access to and redaction of information in the court filing. The opinion text does not describe or decide the underlying claims in the lawsuit.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.