Athena Art Finance Corp. v. that Certain Artwork By Jean-Michel Basquiat Entitled Humidity, 1982, In Rem

District Court, S.D. New York·Decided September 19, 2023·No. 1:20-cv-04669·Unknown

Opinion

September 13, 2023 VIA ECF

The Honorable Valerie Figueredo United States Magistrate Judge United States District Court Southern District of New York 500 Pearl Street, Courtroom 17A New York, New York 10007 Re: Athena Art Finance Corp. v. that Certain Artwork By Jean-Michel Basquiat Entitled Humidity, 1982, in Rem, No. 20-cv-4669 (GBD) (VF); Letter Regarding Sealing Dear Judge Figueredo : We represent Plaintiff and Intervenor-Defendant Athena Art Finance Corp. (“Athena”) in the above-referenced matter and write respectfully in furtherance to the September 08, 2023 correspondences of Interested Parties Delahunty Limited (“Delahunty”) (Dkt. No. 195, the “Delahunty Letter”) and Satfinance Investment Limited (“SIL”) (Dkt. No. 193, the “SIL Letter’) (together, the “Interested Parties” and “Letters”), regarding the sealing of the below exhibits (the “Exhibits”) filed by the Interested Parties in connection to their respective declarations and oppositions to motions for summary judgment (each respective submission, the “Opposition Papers’’): DKT. NUMBER DESCRIPTION BATES STAMP, IF APPLICABLE 203-1 Excerpts from the | N/A deposition transcript of C. Sachs, dated January 6, 2023. 201-1 Excerpts from the | N/A deposition transcript of C. Sachs, dated January 6, 2023. 201-2 Excerpts from the | N/A deposition transcript of G. Danese, dated July 8, 2021.

201-3 Expert report submitted by N/A Michael Plummer, dated February 23, 2023 201-4 Email from I. Philbrick to Athena_00056731–00056734 G. Danese, dated July 11, 2016 201-5 Email from G. Danese to Athena_00057039–00057041 G. Trimarchi et al., dated July 13, 2016 201-6 Email from R. Newland to Athena_00038415–00038420 G. Danese, dated January 11, 2017 201-7 Alleged financial record Athena_Production_UNREDACTED_001647– connected to Inigo 001650 Philbrick Ltd. 201-8 Email from G. Danese to Athena_00043113–00043118 R. Newland, dated March 7, 2017

Athena respectfully submits this letter to assert that the Exhibits above are permitted to be sealed without this Court’s prior permission under paragraph I(D)(i) of the Individual Rules and Practices of Judge George B. Daniels on the basis that they contain “sensitive information” and “proprietary or trade secret information,” read in conjunction with paragraph I(g) of your Honor’s Individual Practices in Civil Cases. Athena also submits that the Exhibits may otherwise be appropriately sealed for the reasons described below. Athena seeks sealing of only an additional nine of the dozens of exhibits filed by the parties in connection with their Opposition Papers, together with the exhibits filed with their original moving papers numbering well over a hundred documents: • The first three documents (Dkt. Nos. 203-1, 201-1, 201-2) are excerpted testimony from former Athena C-suite officers discussing highly sensitive conversations and strategies related to Athena’s internal business practices and lending strategies. For example, the deposition of C. Sachs, designated as confidential, is presented as 30(b)(6) witness testimony on behalf of Athena, testifying to specific and highly confidential considerations and acts Athena would take in connection with their secured lending practices. This testimony reveals sensitive and proprietary trade secrets. • The remaining five documents (Dkt. Nos. 201-4, 201-5, 201-6, 201-7, 201-8) are emails and records describing highly sensitive communications and practices dealing with Athena’s secured lending business. This includes borrower financial information, alleged bank documents, and Athena’s loan structuring practices and considerations. All of these are highly sensitive information or proprietary trade secrets related to Athena’s business. • The Exhibits include an expert report (Dkt. No. 201-3), which purports to opine on Athena’s lending practices and related communications as set forth in the documents above, and cites extensively to those documents already sealed as part of the Court’s prior order. (See Order Granting Letter Motion to Seal, Dkt. No. 186.) Public disclosure of these Exhibits will harm Athena by providing highly confidential, proprietary and trade secret information to Athena’s art lending competitors, which include auction houses such as Sotheby’s Financial Services and Christie’s Art Finance, as well as numerous non-bank art lenders, in a highly competitive market. It would also be harmful to Athena’s business by making public its loan underwriting framework, developed over many years, at great expense. The Exhibits listed above include examples Athena’s underwriting and due diligence practices, the communications related to the collection and review of proprietary diligence materials (including forms drafted by Athena), along with the sensitive and confidential collected borrower information, all of which inform Athena’s decisions whether to extend loans. Although there is a presumption of public access to judicial documents, that presumption may be overcome if “sealing is necessary to preserve higher values and only if the sealing order is narrowly tailored to achieve that aim.” Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 124 (2d Cir. 2006). The Court must determine the extent to which the presumption applies based on the “role of the material at issue.” Id. at 119. Courts in this District recognize that “the presumption of access may be outweighed when there are considerations of the need to conceal confidential business information that could harm a defendant’s competitive position or reveal a trade secret.” JMG Improvements, Inc. v. Arch Specialty Insurance Co., 20 Civ. 2882, 2021 WL 3173022, at *3 (S.D.N.Y. July 26, 2021) (sealing excerpts of an insurance claim manual); See also Rowe v. Google LLC, 19 Civ. 8655, 2022 WL 4467628, at *2 (S.D.N.Y. Sept. 26, 2022) (“the risk of competitive harm outweighed the public right of access” where the redacted information comprised of “strategic business initiatives” and client identities were “unnecessary to adjudicate” summary judgment arguments). Additionally, Courts in this district have recognized the need to redact non-public, otherwise undisclosed personal information of clients, particularly where such information is not at issue in the dispute. See KeyBank Nat’l Ass’n. v. Element Transportation LLC, 16 Civ. 8958, 2017 WL 384875, at *3 (S.D.N.Y. Jan. 26, 2017) (permitting redactions of “narrowly tailored” and “irrelevant nonparty financial information” of borrowers); Cohen v. Gerson Lehrman Group, Inc., 09 Civ. 4352, 2011 WL 4336679, at *2 (S.D.N.Y. Sept. 15, 2011) (permitting redactions of narrowly tailored client information, along with phone numbers and addresses not disputed in the case). Here, sealing is warranted on both bases. First, the portions of the Exhibits Athena seeks to redact are examples of Athena’s proprietary lending strategies in action, including documents that Athena relies upon to extend loans to prospective borrowers, the documents reviewed in connection to Athena’s proprietary lending strategies, and the internal considerations and weight that Athena attributes to them. The assessment methodologies, documents, and related communications used by Athena are valuable, proprietary trade secret information that have never been made available outside of Athena except to prospective borrowers. Their public disclosure would cause direct harm to Athena. See JMG Improvements, Inc., 2021 WL 3173022, at *3 (sealing insurance claim manual not available outside of the company and created with “substantial expense”); Rubik’s Brand Limited v. Flambeau, Inc., 7-CV- 6559, 2021 WL 1085338, at *2 (S.D.N.Y. Mar. 22, 2021) (redacting confidential product and marketing information); Playtex Products, LLC v. Munchkin, Inc., 14-cv-1308, 2016 WL 12776450, at *11 (S.D.N.Y. Mar. 29, 2016) (redacting based on the privacy interests and harm relating to disc

Free access — add to your briefcase to read the full text and ask questions with AI

Athena Art Finance Corp. v. that Certain Artwork By Jean-Michel Basquiat Entitled Humidity, 1982, In Rem, (S.D.N.Y. 2023).

Athena Art Finance Corp. v. that Certain Artwork By Jean-Michel Basquiat Entitled Humidity, 1982, In Rem (Athena Art Finance Corp. v. that Certain Artwork By Jean-Michel Basquiat Entitled Humidity, 1982, In Rem) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Lugosch v. Pyramid Co. of Onondaga
435 F.3d 110 (Second Circuit, 2006)