Criscuolo v. Brandow
- Ona Wang
- 1:23-cv-02406
- U.S. District Court · Southern District of New York
- 1
Criscuolo v. Brandow: Judge Wang granted sealing, denied counsel disqualification, and denied ECF Nos. 9 and 18 as moot.
Petitioner Anthony Criscuolo’s requests were affected: his motion to seal was granted, his motion to disqualify counsel was denied, and ECF Nos. 9 and 18 were denied as moot. Respondent Stephen G. Brandow’s letter response to the sealing motion was noted by the court.
What happened
Criscuolo v. Brandow concerned several requests filed by Petitioner Anthony Criscuolo, including a request to seal materials and a request to disqualify counsel.
Although Criscuolo was represented by counsel, he filed the disqualification request without counsel. The court relied on precedent stating that a represented party has no right to add personal filings to the lawyer’s work.
Judge Ona T. Wang granted the motion to seal, denied the motion to disqualify counsel, and denied ECF Nos. 9 and 18 as moot. She directed the Clerk of Court to close ECF Nos. 9, 11, 18, and 22.
The detailed version
- Criscuolo v. Brandow · No. 1:23-cv-02406
- Ona Wang
- Oct. 19, 2023
Motions and Rulings
The court considered Petitioner Anthony Criscuolo’s motion to seal and Respondent Stephen G. Brandow’s letter response. The court granted the motion to seal, identified as ECF No. 11.
The court also considered Criscuolo’s motion to disqualify counsel, identified as ECF Nos. 22–24. The opinion states that Criscuolo was represented by counsel but filed this motion without counsel. The court denied ECF No. 22, citing a Second Circuit decision holding that a person represented by counsel has no right to supplement the lawyer’s work with selected personal filings.
The court denied ECF Nos. 9 and 18 as moot, meaning those matters no longer required a ruling. The Clerk of Court was directed to close ECF Nos. 9, 11, 18, and 22.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.