John Marcelletti, on behalf of himself and all others similarly situated v. GEICO General Insurance Company

CourtDistrict Court, W.D. New York
DecidedFebruary 26, 2026
Docket6:23-cv-06211
StatusUnknown

This text of John Marcelletti, on behalf of himself and all others similarly situated v. GEICO General Insurance Company (John Marcelletti, on behalf of himself and all others similarly situated v. GEICO General Insurance Company) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John Marcelletti, on behalf of himself and all others similarly situated v. GEICO General Insurance Company, (W.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

JOHN MARCELLETTI, on behalf of himself and all others similarly situated, DECISION AND ORDER Plaintiff, v. 6:23-CV-06211 EAW CDH

GEICO GENERAL INSURANCE COMPANY,

Defendant

INTRODUCTION

In this putative class action, plaintiff John Marcelletti (“Plaintiff”) asserts a claim for breach of contract based on defendant GEICO General Insurance Company’s (“GEICO” or “Defendant”) failure to pay sales tax as part of the “actual cash value” for total loss vehicles. (Dkt. 1). Presently before the Court is Defendant’s motion to seal information submitted as part of the briefing on Plaintiff’s amended motion for class certification, the briefing on the parties’ motions to limit and/or exclude witnesses in connection with class certification, and the exhibits submitted in connection therewith. (Dkt. 190). For the reasons that follow, Defendant’s motion to seal is granted in part and denied in part. BACKGROUND This case has been referred to the undersigned for all non-dispositive pretrial matters. (Dkt. 28; Dkt. 74). Familiarity with the background of this case is assumed for the purposes of this Decision and Order, and the procedural history of this matter is discussed only in relevant part. The Court has ordered the parties in this case to use a bundling procedure for filing any papers submitted in connection with Plaintiff’s amended motion for class

certification. (Dkt. 111; Dkt. 112). On March 5, 2025, the Court issued a Third Amended Scheduling Order that outlines the bundling procedure and sets forth the applicable deadlines. (Dkt. 113). As relevant here, the Third Amended Scheduling Order provides: To the extent any party seeks to seal any papers submitted in connection with the anticipated amended class certification motion and/or response/reply or in connection with any motion to limit or exclude witnesses in connection with class certification and/or response/reply, that party shall take all steps necessary to submit a narrowly tailored and properly supported motion to seal, including conferring with opposing counsel and any relevant third-parties regarding the need for confidentiality. The parties shall, if possible, file a joint motion to seal concerning all documents submitted in support of the anticipated amended class certification motion and/or response/reply and in support of any motion to limit or exclude witnesses in connection with class certification and/or response/reply, that the parties believe should be sealed.

(Id. at 4-5). On December 22, 2025, Defendant filed a motion to seal portions of the briefs and exhibits submitted in connection with: (1) Plaintiff’s amended motion for class certification; (2) Defendant’s motion to exclude the declaration and opinions of Bradley M. Braun, Ph.D.; (3) Plaintiff’s motion to strike and/or exclude portions of Dr. Jonathan T. Tomlin’s Testimony and Expert Report; and (4) Plaintiff’s motion to exclude or limit the opinions of Defendant’s proposed expert Steven R. Wybo. (Dkt. 190).1 Contemporaneously with filing its motion to seal, Defendant submitted to the Court the relevant briefs and exhibits, in which text has been highlighted to indicate the material that Defendant seeks to have redacted on the public docket. In total,

Defendant makes 84 sealing requests,2 though many of the requests are duplicative, as the underlying information is included in exhibits submitted in connection with more than one brief. Defendant groups its proposed redactions into five categories of information: (1) “GEICO’s Processes/Procedures Related to Total Loss Coverage”; (2) “GEICO’s Processes/Procedures Related to Leased Vehicles”; (3) “How GEICO’s Data is Maintained and Accessed”; (4) “Analysis of Vehicle Valuations”; and (5) “Personally

Identifying Information of a Putative Class Member.” (Dkt. 191-1 at 5-9). As with the previous motions to seal it has filed in this case (Dkt. 51; Dkt. 123; Dkt. 131; Dkt. 137; Dkt. 149; Dkt. 154; Dkt. 165; Dkt. 170), Defendant primarily asserts that information in these briefs and exhibits should be sealed because of the risk of competitive harm. (See Dkt. 191 at 8-11). In support of its assertions of competitive harm, Defendant has submitted two

declarations—one by Kevin Costigan, a GEICO employee and one of Defendant’s designated witnesses, and one by James (Jim) Maynard, a consultant “retained by GEICO to opine on certain documents and information” covered by the motion to seal.

1 Plaintiff did not make any sealing requests or submit a response to Defendant’s motion to seal.

2 The Court adopts Defendant’s numerical designations (see Dkt. 191-1 at 5-9) for the purposes of addressing particular sealing requests. (See Dkt. 191-1 at 11-20). The Costigan declaration is substantively similar to declarations that Defendant has submitted with each of its previous motions to seal (see, e.g., Dkt. 155-1 at 31-33) and generally states that if a competitor were to learn

about the information covered by the proposed redactions, “the competitor could use that information to its own economic advantage, to GEICO’s economic disadvantage, and could gain a competitive advantage over GEICO and could cause GEICO substantial economic harm.” (Dkt. 191-1 at 11-14). The Maynard declaration puts forth more specific explanations as to why disclosure of each of the aforementioned categories of information would cause GEICO economic harm. (Id. at 17-20). DISCUSSION

I. Legal Standard “As the Second Circuit has explained, the question of whether the public must be allowed access to a court filing implicates both the common law and the First Amendment.” Hatzimihalis v. SMBC Nikko Sec. Am., Inc., No. 20 CIV. 8037 (JPC), 2023 WL 3736440, at *1 (S.D.N.Y. May 31, 2023) (citing Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 126 (2d Cir. 2006)). “Under the common law framework,

whether a document is a judicial document turns on whether the item is ‘relevant to the performance of the judicial function and useful in the judicial process.’” Id. (quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995)). Under the First Amendment framework, “whether the presumption of public access attaches turns on whether a document bears a close connection to a public judicial proceeding.” Id. (citing Hartford Courant Co. v. Pellegrino, 380 F.3d 83, 93 (2d Cir. 2004)). Under the common law framework, the Court applies a three-step analysis to determine whether a document should be sealed. United Pool Distribution, Inc. v. Custom Courier Sols., Inc., No. 22-CV-06314-FPG, 2024 WL 2979365, at *1 (W.D.N.Y.

June 13, 2024) (citations omitted). At the first step, “the court determines whether the record at issue is a judicial document—a document to which the presumption of public access attaches.” Olson v. Major League Baseball, 29 F.4th 59, 87 (2d Cir. 2022) (quotation omitted). “A document is ‘judicial’ when it is ‘relevant to the performance of the judicial function and useful in the judicial process.’” In re New York City Policing During Summer 2020 Demonstrations, 635 F. Supp. 3d 247, 251 (S.D.N.Y. 2022) (quoting Amodeo, 44 F.3d at 145). “A document is . . . relevant to the

performance of the judicial function if it would reasonably have the tendency to influence a district court's ruling on a motion or in the exercise of its supervisory powers, without regard to which way the court ultimately rules or whether the document ultimately in fact influences the court's decision.” Id. (quoting Brown v. Maxwell, 929 F.3d 41, 49 (2d Cir. 2019)).

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Related

United States v. Amodeo
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John Marcelletti, on behalf of himself and all others similarly situated v. GEICO General Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-marcelletti-on-behalf-of-himself-and-all-others-similarly-situated-v-nywd-2026.