Batta Fulkerson, LLP v. Bulldog Law, P.C.
- Proceeding
- district
- Area
- civil
- Panel
- Guillermo Cabrera (author)
Analysis
The court considered Defendant Bulldog Law, P.C.'s motion to file a Separation Agreement under seal, arguing it contained sensitive business information. The court granted the motion, finding that the defendant established good cause for sealing the document.
| What the court decided | The model |
|---|---|
Motion to File Documents Under Seal granted“Accordingly, the Motion is GRANTED. The Clerk of Court is directed to file under seal the documents lodged at ECF No. 124.” | agree with court The court applied the 'good cause' standard from Kamakana v. City & Cnty. of Honolulu, which is the correct standard for sealing discovery materials under Federal Rule of Civil Procedure 26(c). The court relied on Kimera Labs Inc. v. Exocel Bio Inc. to support the proposition that confidential business information causing competitive harm meets this standard. The order recites the defendant's argument and the legal basis for the decision, making the result defensible based on the cited authorities. |
The order itself: sound — The order correctly identifies the applicable legal standard for sealing discovery materials and applies it to the specific facts presented (sensitive business information/competitive harm). It cites binding Ninth Circuit authority (Kamakana) and persuasive district court authority (Kimera) to support the conclusion. The reasoning is concise but sufficient for a routine sealing motion.
Opinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 BATTA FULKERSON, LLP, Case No.: 25-cv-00551-AGS-GC 12 Plaintiff, ORDER GRANTING DEFENDANT’S 13 v. MOTION TO FILE DOCUMENTS UNDER SEAL 14 BULLDOG LAW, P.C., 15 Defendant. [ECF Nos. 123, 124] 16 AND RELATED COUNTERCLAIM. 17 18 19 Before the Court is a Motion to File Exhibits Under Seal by Defendant Bulldog Law, 20 P.C. (“Defendant”). (ECF No. 123.) Defendant seeks to file under seal Exhibit 6 – 21 Separation Agreement, dated November 1, 2023, which is an Exhibit to Defendant’s 22 Corrected Fourth Amended Supplemental Answers to Answers to Plaintiff’s Revised First 23 Set of Interrogatories. (See ECF Nos. 122-1; 123 at 2; 125 at 37–39, 70–72.) Defendant 24 argues the Separation Agreement contains non-public, sensitive business information, the 25 disclosure of which could cause competitive harm. (ECF No. 123 at 2.) 26 “A ‘good cause’ showing will suffice to seal documents produced in discovery.” 27 Kamakana v. City & Cnty. of Honolulu, 447 F.3d 1172, 1180 (9th Cir. 2006) (citing Fed. 28 R. Civ. P. 26(c)). Here, the Court finds Defendant has established good cause for sealing 1 ||the Separation Agreement. See Kimera Labs Inc. v. Exocel Bio Inc., No, 21-CV-2137- 2 ||MMA-DDL, 2024 WL 3014639, at *1-2 (S.D. Cal. June 14, 2024) (noting that 3 || confidential, sensitive business information that may harm a litigants competitive standing 4 ||meets the good cause standard). 5 Accordingly, the Motion is GRANTED. The Clerk of Court is directed to file under 6 ||seal the documents lodged at ECF No. 124.! 7 IT IS SO ORDERED. 8 || Dated: August 28, 2026 9 10 4.— i 12 Hon. Guillermo Cabrera 13 United States Magistrate Judge 14 15 16 17 18 19 20 21 22 23 25 6 ! Although Defendant lodged under seal all exhibits to its Corrected Fourth Amended Supplemental Answers to Answers to Plaintiff’s Revised First Set of Interrogatories, it also 27 publicly filed all exhibits except for the Separation Agreement. Therefore, all exhibits, 28 with the exception of the Separation Agreement, are publicly available on the docket. (See ECF No. 125.)