Robinson v. De Niro
- Lewis Liman
- 1:19-cv-09156
- U.S. District Court · Southern District of New York
- 3
In Robinson v. De Niro, Judge Liman partly granted and partly denied sealing requests, allowing some exhibits to remain sealed or redacted but rejecting docket filing of trial exhibits.
Graham Chase Robinson, Robert De Niro, Canal Productions, Inc., and members of the public seeking access to the trial exhibits.
What happened
In Robinson v. De Niro, Graham Chase Robinson asked the court to keep some trial exhibits under seal, allow limited redactions to others, and require the parties to file trial exhibits with the redactions used at trial.
The court allowed Defendants’ Trial Exhibit 76 to remain sealed and required email addresses and telephone numbers to be redacted from Exhibit 82. It fully granted Robinson’s requests concerning Exhibits 99, 139, 195, 98, and 156. But it denied the request to require the parties to file their trial exhibits on the public docket.
Judge Lewis J. Liman ruled that the public had been able to attend the trial and view and take notes on the exhibits, so the court declined to order their docket filing. The court directed the Clerk to close the motions concerning docket entries 438, 451, and 457.
The detailed version
- Robinson v. De Niro · No. 1:19-cv-09156
- Lewis Liman
- Nov. 22, 2023
Background
Graham Chase Robinson moved to: (1) keep Defendants’ Trial Exhibits 76 and 82 under seal; (2) file her Trial Exhibits 99, 139, and 195 with limited redactions; and (3) file her Trial Exhibits 98 and 156 with limited redactions. She also asked the court to require the parties to file their trial exhibits on the public docket with the redactions used at trial, subject to two exceptions for sensitive exhibits.
Legal standard
The court explained that judicial documents generally carry a common-law presumption of public access. To decide whether sealing is appropriate, the court considers whether the material is a judicial document, the strength of the public-access presumption, and countervailing interests that weigh against access. Sealing requires an individual review of the documents and specific findings that sealing is necessary to protect higher values.
Rulings
The court granted in part the motion at Docket No. 438: Defendants’ Trial Exhibit 76 may remain under seal, while Exhibit 82 must be filed with email addresses and telephone numbers redacted.
The court granted in full the motions at Docket Nos. 451 and 457.
The court denied Robinson’s request at Docket No. 503 to require the parties to file their trial exhibits on the docket with the redactions used at trial. The court stated that the courtroom was open to the public and that members of the public could view and take notes on the trial exhibits. The court therefore declined to order the exhibits filed on the docket.
The Clerk of Court was directed to close the motions at Docket Nos. 438, 451, and 457.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.