AMERICAN BOARD OF INTERNAL MEDICINE v. JAMIE SALAS RUSHFORD, M.D.

CourtDistrict Court, D. New Jersey
DecidedMarch 31, 2025
Docket2:14-cv-06428
StatusUnknown

This text of AMERICAN BOARD OF INTERNAL MEDICINE v. JAMIE SALAS RUSHFORD, M.D. (AMERICAN BOARD OF INTERNAL MEDICINE v. JAMIE SALAS RUSHFORD, M.D.) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AMERICAN BOARD OF INTERNAL MEDICINE v. JAMIE SALAS RUSHFORD, M.D., (D.N.J. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

AMERICAN BOARD OF INTERNAL MEDICINE, Civil No.: 14-cv-6428 (KSH) (CLW) Plaintiff,

v. JAMIE SALAS RUSHFORD, M.D., OPINION Defendant.

Katharine S. Hayden, U.S.D.J. I. Introduction Two applications are before the Court. First is the motion filed by plaintiff American Board of Internal Medicine (“ABIM”) (D.E. 234) to maintain under permanent seal the Court’s September 30, 2024 summary judgment opinion and to have redactions applied to the forthcoming publicly available copy of the opinion. Second is the appeal (D.E. 235) by defendant Dr. Jaime Salas Rushford (“Salas Rushford”) from Magistrate Judge Cathy L. Waldor’s ruling (D.E. 232) denying reconsideration of her earlier order (D.E. 222) permitting portions of the summary judgment motion record to remain under permanent seal. II. Background A. Procedural History As has been discussed in the Court’s prior rulings and throughout this litigation, Salas Rushford sat for and passed the 2009 administration of ABIM’s internal medicine board certification exam. ABIM later accused him of infringing its copyrighted exam material by emailing it to Dr. Rajender Arora (“Arora”), the proprietor of a test-preparation company, ABR, whose review course Salas Rushford had attended. On September 30, 2024, this Court granted Salas Rushford’s motion for summary judgment on ABIM’s copyright infringement claim against him, which by then was the only remaining claim. The papers on the summary judgment motion were at that point partially filed under seal awaiting the outcome of motion practice pending before Judge Waldor. As such, this Court filed its opinion, which cited aspects of the

summary judgment motion record, under seal, and in the accompanying order directed the parties to file an appropriate motion to seal by October 9, 2024 if they sought to retain the opinion, or any portion of it, under seal. (D.E. 227.) On October 7, 2024, the Court extended that deadline, ordering that the opinion would remain under temporary seal until Judge Waldor ruled on the motion pertaining to the summary judgment motion record. (See D.E. 229.) The Court directed the parties to confer to narrow or eliminate their sealing contentions as to the opinion, given that the interest in public access to judicial opinions is particularly strong. (Id.) On November 25, 2024,1 Judge Waldor issued an order (D.E. 232) adhering to her previous ruling (D.E. 222) that portions of the motion record

could remain permanently sealed. The next day the Court issued this text order setting a briefing schedule for the motion directed to the sealing of the summary judgment opinion: The strong presumption of openness governing judicial records, which, among other virtues, promotes confidence in and respect for, the judicial process, is particularly acute with respect to judicial opinions, and a litigant seeking to limit the public’s access to any part of a judicial opinion has a high burden to overcome. This Court’s summary judgment opinion [D.E. 226] was issued nearly two months ago and remains under seal [D.E. 229]; there is no reason to further delay submissions on why that opinion should not be unsealed in full. Should either party seek to maintain the unredacted opinion under seal, that party shall file a motion to seal no later than December 6, 2024. A proposed redacted version of the opinion shall be included with the motion. Opposition to the motion shall be filed by December 13, 2024. To the extent the movant intends to assert the

1 The decision was issued on November 25 but entered the next day, making Salas Rushford’s December 10, 2024 appeal (discussed below) timely. rights of any nonparty, the movant shall address its standing to do so and its submission shall reflect the position of the nonparty with respect to the motion.

(D.E. 233.) On December 6, 2024, ABIM filed its motion to seal the summary judgment opinion, seeking 15 redactions, all of which relate to Dr. Geraldine Luna, a former colleague of Salas Rushford who became a witness against him in this litigation. (D.E. 234.) In support of its motion, ABIM submitted an attorney declaration (D.E. 234-1, Declaration of Paul Lantieri III, Esq. dated Dec. 6, 2024 (“12/6/24 Lantieri Decl.”)), attaching an index of proposed redactions in the form specified by L. Civ. R. 5.3. Salas Rushford timely opposed on December 13, 2024. (D.E. 236.) On December 10, 2024, Salas Rushford appealed to this Court from Judge Waldor’s November 25 order maintaining the seal on portions of the summary judgment record. (D.E. 235.) ABIM timely opposed on December 23, 2024. (D.E. 239.) B. Subject Material To provide context for the Court’s analysis of the parties’ positions on both applications before the Court, it is necessary to discuss the summary judgment filings in some detail. ABIM filed its motion for summary judgment under seal on February 9, 2024. (D.E. 207.) In a February 19, 2024 letter, Salas Rushford opposed “sealing any filings at this advanced stage in the case,” asserting that “[t]here is no justification for confidentiality that would overcome the strong presumption of full public access” to what ABIM was relying on to make its motion. (D.E. 209.) He targeted, in particular, references contained in ABIM’s motion papers

and his anticipated cross-motion to Luna, whom he described as a “key witness of ABIM.” (Id. at 1.) He sought permission to make arguments about Luna “without redaction in our brief and, to the extent relevant, to file th[e] ABIM-Luna settlement agreement on the public docket along with our other exhibits.” (Id. at 1-2.) On February 20, 2024, Judge Waldor directed ABIM to file a redacted version of its summary judgment motion and to file an appropriate motion to seal after conferring with Salas Rushford.2 (D.E. 210.) ABIM’s unredacted summary judgment motion, D.E. 207, would remain sealed until further order. (Id.) ABIM filed a redacted, publicly available version of its summary judgment motion the same day. (D.E. 211.) Its brief and Rule 56.1 statement were

redacted, and two exhibits – exhibit 12, Luna’s deposition transcript, and exhibit 22, the deposition transcript of an investigator working for ABIM, Benjamin Mannes – were omitted, with slipsheets in their place. (See D.E. 211-1 (redacted moving brief); D.E. 211-2 (redacted R. 56.1 statement); D.E. 211-14 (slipsheet for exhibit 12); D.E. 211-24 (slipsheet for exhibit 22).) On March 1, 2024, Salas Rushford opposed ABIM’s summary judgment motion and cross-moved for summary judgment in his favor. (D.E. 212.) This filing, which included a brief, a responsive Rule 56.1 statement, a Rule 56.1 statement in support of the cross-motion, and various exhibits (among them, excerpts from Luna’s deposition transcript; Luna’s settlement agreement with ABIM; a related email; and excerpts from Mannes’s deposition transcript), was

not redacted or made under seal. Whether Salas Rushford was intentionally flouting Judge Waldor’s order is unclear, but ABIM did not object or seek to have the filing temporarily sealed. Three weeks later, on March 22, 2024, ABIM filed a combined reply in support of its summary judgment motion and opposition to Salas Rushford’s cross-motion. It filed a redacted version (D.E. 214) and an unredacted version under seal (D.E. 215). On April 5, 2024, Salas Rushford filed his reply brief. (D.E. 216.) It was neither redacted nor filed under seal. ABIM did not object or seek temporary sealing.

2 L. Civ. R. 5.3 requires a single, consolidated motion to seal to be filed after briefing on the underlying motion concludes. L. Civ. R. 5.3(c)(1), (2)(ii). Under L. Civ. R. 5.3, a motion to maintain any of the summary judgment motion record under seal was due on April 19, 2024, i.e., 14 days after Salas Rushford filed his reply brief. L. Civ. R. 5.3(c)(2)(ii).

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AMERICAN BOARD OF INTERNAL MEDICINE v. JAMIE SALAS RUSHFORD, M.D., Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-board-of-internal-medicine-v-jamie-salas-rushford-md-njd-2025.