Bush Truck Leasing, Inc. v. All Ways Auto Transport, LLC

District Court, S.D. Ohio·Decided February 4, 2025·No. 1:20-cv-00511·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

BUSH TRUCK LEASING, INC., Case No. 1:20-cv-511 Plaintiff, Dlott, J. Litkovitz, M.J. vs.

ALL WAYS AUTO TRANSPORT, LLC, ORDER Defendant. This matter is before the Court on plaintiff/counter-defendant Bush Truck Leasing, Inc. (Bush’s) motion to file documents under seal. (Doc. 178). Non-party Dickinson Fleet Services, LLC (Dickinson) filed a memorandum in support of Bush’s motion. (Doc. 184). I. Motion to Seal A. Standard of Review Under the Court’s local rules, “parties may not file documents under seal without obtaining leave of Court upon motion and for good cause shown.” S.D. Ohio Civ. R. 5.2.1(a). A court’s discretion to seal its own records and files is limited by the “‘strong presumption in favor of openness’ as to court records.” Shane Grp., Inc. v. Blue Cross Blue Shield of Mich., 825 F.3d 299, 305 (6th Cir. 2016) (quoting Brown & Williamson Tobacco Corp. v. F.T.C., 710 F.2d 1165, 1179 (6th Cir. 1983)). See also Nixon v. Warner Commc’ns, Inc., 435 U.S. 589, 598 (1978) (“Every court has supervisory power over its own records and files.”). This openness presumption owes to the public’s “strong interest in obtaining the information contained in the court record . . . [including] an interest in ascertaining what evidence and records” a court relies upon for its decisions. Lipman v. Budish, 974 F.3d 726, 753 (6th Cir. 2020) (quoting Brown & Williamson, 710 F.2d at 1180-81). The party seeking to seal court records carries the heavy burden of overcoming this presumption, and “[o]nly the most compelling reasons can justify non-disclosure of judicial records.” Shane Grp., 825 F.3d at 305 (quoting In re Knoxville News- Sentinel Co., Inc., 723 F.2d 470, 476 (6th Cir. 1983)). Additionally, the Court is required to set forth specific findings and conclusions justifying the sealing of records—regardless of whether a party objects. Id. at 306. To justify sealing records, the proponent must demonstrate: “(1) a compelling interest in

sealing the records; (2) that the interest in sealing outweighs the public’s interest in accessing the records; and (3) that the request is narrowly tailored.” Kondash v. Kia Motors Am., Inc., 767 F. App’x 635, 637 (6th Cir. 2019) (citing Shane Group, 825 F.3d at 305). The proponent must also “analyze in detail, document by document, the propriety of secrecy, providing reasons and legal citations.” Shane Grp., 825 F.3d at 305-06 (quoting Baxter Intern., Inc. v. Abbott Lab’ys, 297 F.3d 544, 548 (7th Cir. 2002)). As relevant here, the Sixth Circuit recognizes certain content-based exceptions to the presumption of openness related to “certain privacy rights of participants or third parties. . . .” Brahmamdam v. TriHealth, Inc., No. 1:19-cv-152, 2021 WL 5005368, at *2 (S.D. Ohio Oct. 27, 2021) (quoting Brown & Williamson, 710 F.2d at 1179). In the context of civil litigation, this

exception is generally limited to “only trade secrets, information covered by a recognized privilege, and information required by statute to be maintained in confidence. . . .” Id. (quoting Reese on Behalf of Fifth Third Bancorp v. Carmichael, No. 1:20-cv-886, 2020 WL 6810921, at *1 (S.D. Ohio Nov. 16, 2020)). B. Analysis Bush’s motion is twofold. First, Bush seeks to file a limited portion of Dickinson’s Rule 30(b)(6) representative David Henchon’s deposition under seal. Second, Bush seeks to file a redacted version of its Rule 26(a)(2)(C) expert disclosure and report of Andy Vidourek. 1. Deposition excerpt District Judge Dlott’s Standing Order provides that deposition transcripts must be filed in their entirety except for good cause shown. See District Judge Dlott’s Standing Order on Civil Procedures, I.E.3.b. In its motion for partial summary judgment, AWA relies for one of its arguments on a quoted portion of an agreement between Dickinson and Love’s Travel Stops &

Country Stores, Inc. (Love’s). Bush seeks to introduce Mr. Henchon’s deposition testimony only as it relates that agreement/argument. Dickinson, however, has designated this and many other portions of Mr. Henchon’s deposition transcript as confidential. As a result, if the Court requires the filing of the entire deposition transcript, Dickinson—a non-party—would bear the significant burden of justifying the sealing of extensive portions of the deposition that are not at issue in the parties’ summary judgment briefing. Under these circumstances, Bush argues that good cause supports allowing only the relevant excerpt of Mr. Henchon’s deposition to be filed. Bush takes no position, however, on whether this excerpt may or should be sealed under Shane Grp., Inc. Dickinson adds that requiring Bush to file the entire deposition transcript would encompass the deposition exhibits, including the contract with non-party Love’s, which would raise further

confidentiality issues. The Court finds good cause for filing only the proposed excerpt of Mr. Henchon’s deposition in this case, which Bush submitted to the Court for in camera review. AWA did not object to this request, and the excerpt provided addresses the argument AWA placed in issue in its motion for partial summary judgment. The Court reserves the right to request the filing of the full deposition transcript (allowing Bush and Dickinson an opportunity to first brief the appropriateness of sealing) if circumstances change. As to the whether the content of that deposition excerpt may be sealed, Dickinson argues that it contains “confidential testimony about discount and pricing information as well as testimony about the terms of the Love’s Agreement” and that several of this Court’s precedents support sealing this type of information. (Doc. 184 at PAGEID 7831-32). Dickinson argues that the testimony—regarding two non-parties’ business dealings—is tangential to the claims between Bush and AWA and thus of little interest to the public and its understanding of this

dispute. Finally, Dickinson argues that it seeks to seal only six-pages of a significant record. The Court has reviewed the excerpted testimony at issue in camera. Mr. Henchon’s deposition testimony includes information about confidential business negotiations between Dickinson and another non-party, as well as a reference to pricing information on third-party invoices. “This Court has repeatedly ‘recognized that protecting confidential information that would otherwise allow competitors an inside look at a company’s business strategies is a compelling reason to restrict public access to filings.’” Total Quality Logistics, LLC v. Riffe, No. 1:19-cv-23, 2020 WL 5849408, at *2 (S.D. Ohio Sept. 30, 2020) (quoting Ethicon Endo-Surgery, Inc. v. Covidien, Inc., No. 1:11-cv-871, 2017 WL 4168290, at *2 (S.D. Ohio Sept. 20, 2017)). Dickinson has a compelling interest in keeping this information from public view. See London

Computer Sys., Inc. v. Zillow, Inc., No. 1:18-cv-696, 2020 WL 4431478, at *3 (S.D. Ohio July 31, 2020) (“[C]ompanies have a compelling interest in protecting their business strategies from competitors.”). The public’s interest in non-party Dickinson’s confidential business information is limited given the nature of the instant dispute between private parties. See Peyton v. Wilmington Sav. Fund Soc’y, FSB, No. 1:24-mc-0010, 2024 WL 4494233, at *2 (S.D. Ohio Oct. 15, 2024). See also London Comput. Sys., Inc. v.

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

Bush Truck Leasing, Inc. v. All Ways Auto Transport, LLC, (S.D. Ohio 2025).

Bush Truck Leasing, Inc. v. All Ways Auto Transport, LLC (Bush Truck Leasing, Inc. v. All Ways Auto Transport, LLC) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related