in Re: Gita Srivastava

CourtCourt of Appeals of Texas
DecidedFebruary 12, 2018
Docket05-17-00998-CV
StatusPublished

This text of in Re: Gita Srivastava (in Re: Gita Srivastava) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
in Re: Gita Srivastava, (Tex. Ct. App. 2018).

Opinion

Conditionally granted in part, Denied in part, and Opinion Filed February 12, 2018

In The Court of Appeals Fifth District of Texas at Dallas No. 05-17-00998-CV

IN RE GITA SRIVASTAVA, Relator

Original Proceeding from the 470th Judicial District Court Collin County, Texas Trial Court Cause No. 470-05429-2016

MEMORANDUM OPINION Before Justices Lang, Myers, and Boatright Opinion by Justice Myers The underlying proceeding relates to the redaction of certain information included in the

trial court records and trial transcript of bill of review proceedings relating to divorce and parental

termination proceedings. In this original proceeding, relator complains that the trial court refused

to redact certain information from the record of those proceedings that relator contends is sensitive

data requiring redaction either under Rule 21c of the rules of civil procedure or pursuant to

constitutionally-protected privacy interests. Relator seeks a writ of mandamus directing the trial

court to redact the information from the trial transcript1 and documents filed in the trial court. We

conditionally grant the writ in part and deny the writ in part.

1 Relator and the trial court use the term “trial transcript” to describe the court reporter’s record of testimony and argument at trial, and the term “trial exhibits” to describe the exhibits admitted into evidence at trial. The parties have agreed to seal the trial exhibits, but disagree on what should be redacted from the trial transcript. For consistency and to avoid confusion, we refer to the court reporter’s record of testimony and argument at trial as the “trial transcript” rather than as the “reporter’s record.” Background

Relator Gita Srivastava and real party in interest Andrew Greenhut were married in 2007

and, in January 2015, had a child. Srivastava filed for divorce later that year. The trial court

ultimately entered an “Agreed Order of Termination of Parent-Child Relationship” that terminated

Greenhut’s parental rights and entered an “Agreed Final Decree of Divorce.” In 2016, Greenhut

filed two separate bills of review; one challenged the parental termination order and the other

challenged the agreed final divorce decree. Srivastava moved to seal the court records in the bill

of review proceedings. And, on April 17, 2017, the trial court granted Srivastava’s motion to seal

court records. The sealing order states that “all documents bearing” either of the bill of review

cause numbers “are sealed” and “may only be released to either party, an attorney for either party,

or a staff member of an attorney for either party on that attorney’s behalf.” The trial court denied

the bills of review on June 13, 2017. The trial court then held a hearing on its own motion to

unseal the court records in the bill of review proceedings and stated that the court would unseal

the bill of review records on August 25, 2017.

In her petition for writ of mandamus, Srivastava complained that the trial court had not

given the parties a meaningful opportunity to meet and to reach agreements on what sensitive data

should be redacted from the record. Srivastava sought a writ staying the trial court’s decision to

unseal the records until the parties are given a meaningful opportunity to review the trial transcript

and exhibits and request appropriate redactions. We stayed the trial court’s decision to unseal the

records and requested a response to the petition from Greenhut. The trial court then directed the

parties to schedule a conference with the court to review the trial exhibits and filed documents to

identify sensitive data requiring redaction. The trial court also directed the parties to schedule a

hearing for the court to rule on any contested issues relating to the requested redactions.

–2– The trial court then signed an “Order on Redactions of Sensitive Data.” The redaction

order states that the parties agreed to seal the trial exhibits and agreed to file a list of trial transcript

page and line numbers that contain Rule 21c sensitive data for review by the court “and if any

exists, the sensitive data will be protected from release.” The trial court also agreed to permit

redaction of “full personal identification numbers and full financial account numbers” from the

trial transcript “due to privacy concerns,” but found that no such information appears in the

transcript. The redaction order also includes the trial court’s findings regarding Rule 21c and

unsealing the court records. Specifically, the trial court found that the family code requires the

child’s name and date of birth to be included in the court records, Rule 21c “entitles” parties to

redact sensitive data in documents filed with the court but does not require redaction of the

information from the trial transcript, Rule 76a was not followed with respect to sealing the court

records, the child was not a party to or represented by an attorney ad litem in the divorce,

termination, or bill of review proceedings, and the “orders herein are in the best interest of the

child.” The trial court ordered the court reporter to seal the trial exhibits from the bill of review

proceedings and to redact an address in the trial transcript that might be the child’s home address.

The court also ordered the district clerk to seal three specific pleadings and noted that the redacted,

substituted versions of pleadings and orders containing sensitive data had been provided to the

district clerk.

Srivastava then filed a “Status Report Filed Under Seal” with this Court, complaining that

the redaction order did not redact all sensitive data and should be vacated or modified. We treat

the status report as an amended petition. In that status report. Srivastava asks for a writ ordering

the district court to either redact the remaining sensitive data from the trial transcript and pleadings

or order the district court to partially vacate its redaction order to the extent that order unseals the

documents containing the sensitive data. Srivastava also asks the Court to order the district court

–3– to partially vacate the redaction order to the extent it unseals documents from the original divorce

and termination proceedings that were sealed in those cases by agreement and attached as exhibits

to pleadings in the two bills of review. The real party in interest filed a response to Srivastava’s

“status report filed under seal,” and Srivastava filed a reply brief.

Standard of Review

To be entitled to mandamus relief, a relator must show both that the trial court has clearly

abused its discretion and that relator has no adequate appellate remedy. In re Prudential Ins. Co.,

148 S.W.3d 124, 135–36 (Tex. 2004) (orig. proceeding). “Documents once unsealed cannot

effectively be resealed after appeal.” Upjohn Co. v. Marshall, 843 S.W.2d 203, 205 (Tex. App.—

Dallas 1992, no writ). There is, thus, no adequate remedy by appeal of an erroneous order

requesting a party to produce privileged or protected documents. In re York Risk Servs. Group,

Inc., No. 12-17-00210-CV, 2017 WL 5622951, at *2 (Tex. App.—Tyler Nov. 22, 2017, orig.

proceeding); Pittsburgh Corning Corp. v. Caldwell, 861 S.W.2d 423, 424 (Tex. App.—Houston

[14th Dist.] 1993, orig.

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

Related

In Re Prudential Insurance Co. of America
148 S.W.3d 124 (Texas Supreme Court, 2004)
In Re Higgins
246 S.W.3d 744 (Court of Appeals of Texas, 2007)
General Tire, Inc. v. Kepple
970 S.W.2d 520 (Texas Supreme Court, 1998)
Jamar v. Patterson
868 S.W.2d 318 (Texas Supreme Court, 1994)
Pittsburgh Corning Corp. v. Caldwell
861 S.W.2d 423 (Court of Appeals of Texas, 1993)
Upjohn Co. v. Marshall
843 S.W.2d 203 (Court of Appeals of Texas, 1992)
Standard Fire Insurance Co. v. Christy Jean Wand LaCoke
585 S.W.2d 678 (Texas Supreme Court, 1979)
Boardman v. ELM Block Development Ltd. Partnership
872 S.W.2d 297 (Court of Appeals of Texas, 1994)
Walker v. Packer
827 S.W.2d 833 (Texas Supreme Court, 1992)
In Re Anderson
973 S.W.2d 410 (Court of Appeals of Texas, 1998)
Brett Shipp v. Dr. Richard Malouf and Leanne Malouf
439 S.W.3d 432 (Court of Appeals of Texas, 2014)
In re M-I L.L.C.
505 S.W.3d 569 (Texas Supreme Court, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
in Re: Gita Srivastava, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-gita-srivastava-texapp-2018.