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S.D.N.Y.Procedural orderFiled Apr. 24, 2024

Gravitas Search Partners LLC v. Deutsch

Judge
Garnett
Docket
1:24-cv-02683
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedureMotion to Dismiss
In one sentence

In Gravitas Search Partners LLC v. Deutsch, Judge Garnett granted in part and denied in part a request to seal documents, requiring some public filings.

Who this affects

Defendant Jennifer A. Deutsch may keep Exhibit 2 under seal and file a redacted brief. Gravitas Search Partners LLC and the public will have access to the unredacted declaration and Exhibits 4 through 8. Certain non-parties whose sensitive information appears in Exhibit 2 are also affected.

What happened

In Gravitas Search Partners LLC v. Deutsch, Defendant Jennifer A. Deutsch asked to file a redacted brief and declaration and to seal several exhibits while supporting her motion to dismiss. Plaintiff Gravitas Search Partners LLC responded.

The court found that Exhibit 2 contained highly sensitive information about non-parties’ candidacies and interest in a client of Gravitas. The court also found that the proposed redactions in Deutsch’s brief discussed that information. Exhibits 4 through 8, however, were screenshots of publicly available webpages.

Judge Margaret M. Garnett granted in part and denied in part Deutsch’s request. She allowed Deutsch to file the proposed redacted brief and Exhibit 2 entirely under seal, but ordered public, unredacted filings of the declaration and Exhibits 4 through 8. The court also directed the Clerk to terminate the sealing motion.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Gravitas Search Partners LLC v. Deutsch · No. 1:24-cv-02683
Judge
Garnett
Date
Apr. 24, 2024

Background

Defendant Jennifer A. Deutsch asked for permission to file a redacted version of her memorandum supporting her motion to dismiss and a redacted version of the supporting declaration of Emily Reisbaum. She also asked to file Exhibits 2 and 4 through 8 entirely under seal. Gravitas Search Partners LLC responded to the request.

Court’s analysis

The court explained that judicial documents generally carry a common-law presumption of public access, although that right is not absolute. Courts must balance that presumption against competing considerations based on the facts of the particular case.

The court determined that Exhibit 2 contained highly sensitive and confidential information about certain non-parties, including information about their candidacies and interest in a non-party client of Gravitas. The court also determined that the proposed redactions in Deutsch’s memorandum discussed the nature of Exhibit 2 and the sensitive information it contained. By contrast, Exhibits 4 through 8 were screenshots of publicly available webpages.

Ruling

The court granted in part and denied in part Deutsch’s letter-motion. Deutsch may file the proposed redacted version of her memorandum and may file Exhibit 2 entirely under seal. She must publicly file unredacted and unsealed versions of Reisbaum’s declaration and Exhibits 4 through 8. The Clerk of Court was directed to terminate Docket No. 11. The order did not decide the underlying motion to dismiss.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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