Lawson v. Paramount Global and Black Entertainment Television LLC

• Court: District Court, S.D. New York
• Decided: October 23, 2025
• Docket: 1:24-cv-03315
• Status: Unknown

Opinion

KA Mc GUIRE MARGOLIS LLP 810 SEVENTH AVENUE ® 33RD FLOOR New York, NY 10019 MARJORIE B. KULAK TELEPHONE (212) 644-1010 New York DIRECT DIAL: (212) 909-0721 FAX (212) 644-1936 DIRECT FAX: (212) 909-3521 Los ANGELES KULAK@KMM.COM WWW.KMM.COM October 15, 2025 VIA ECF Hon. Dale E. Ho, U.S.D.J. United States District Court, SDNY 40 Foley Square New York, NY 10007

Re: | Lawson v. Paramount Global and Black Entertainment Television LLC, Case No. 1:24-cv-03315 Dear Judge Ho: We represent Defendants Paramount Global and Black Entertainment Television LLC (“BET”) (together, “Defendants”) in the referenced matter. We write, together with counsel for Plaintiff Keith Lawson (“Plaintiff’), to request permission for the parties to file the letter motions identified in the Court’s October 9, 2025 Order (“letter motions”) under seal. These letter motions set forth, among other things, the record evidence regarding whether Fania N. Washington, Esq., Senior Vice President, Employment Law, acted as a fact-finder and conducted an investigation regarding Plaintiff. The parties request that their letter motions and supporting exhibits be filed under seal because these letter motions attach and discuss documents that have been designated as Confidential Discovery Material under the March 5, 2025 Confidentiality Stipulation and Order (“Confidentiality Stipulation”) in this matter. Pursuant to Section 11 of such Confidentiality Stipulation: Any Confidential Discovery Material filed or to be filed with the Court shall be filed under seal and any copies thereof shall be held in confidence as provided in this Stipulation. Accordingly, any and all dispositive motions or papers filed with the Court which reference Confidential Discovery Material as an exhibit, will be filed under seal so as not to inadvertently disclose the content of the Confidential Discovery Material. (Docket No. 21, J 11.) Further, the parties’ letter motions, and their attached documents, set forth information regarding Plaintiff's employment history and Defendants’ confidential and proprietary information, which are subjects that the Court recommends that parties exercise “caution” with respect to public filing in its Notice Regarding Privacy and Public Access to Electronic Civil and Criminal Case Files. Additionally, the parties’ letter motions and attached documents: (a) contain sensitive information regarding a third party; and (b) Defendants have

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certain contractual confidentiality obligations to this third party. The parties therefore jointly request permission to file their letter motions under seal. Respectfully submitted, /s/ Marjorie B. Kulak Marjorie B. Kulak CC: Andrew Goodstadt, Esq., Counsel for Plaintiff cation DENIED WITHOUT PREJUDICE. The documents in question are submitted in connection with a dispute, rendering them judicial documents, to which a presumption of public access attaches. See JBM Co. Focus (US), Inc., No. 22 Civ. 9910, 2024 WL 970907, at *1 (S.D.N.Y. Feb. 29, 2024). The mere existence of order, without more, does not defeat the presumption of public access to judicial documents. See Luge Co. of Onondaga, 435 F.3d 110, 125-26 (2d Cir. 2006). Rather, "continued sealing of [such] documents ma‘ only with specific, on-the-record findings that sealing is necessary to preserve higher values and only if the s is narrowly tailored to achieve that aim." Brown v. Maxwell, 929 F.3d 41, 47 (2d Cir. 2019) (internal quotation omitted). "higher values" that may justify sealing or redactions may include various interests asserted here (if properly inv the privacy interests of third parties, see Matter of New York Times Co., 828 F.2d 110, 116 (2d Cir. 1987), o proprietary business information, such as trade secrets, confidential research, and revenue or pricing the disclosure of which may advantage a business's competitors, see Kewazinga Corp. v. Microsoft Corp 4500, 2021 WL 1222122, at *6 (S.D.N.Y. Mar. 31, 2021). The Court is unaware at this time, however, of any for the proposition that a party's "employment history" may be shielded from public disclosure when submit a judicial document. In any event, because the parties’ request for categorical sealing is not explained with ade nor narrowly tailored in the form of proposed redactions, the request is DENIED. the parties may file a renewed motion to permanently maintain the subject documents (ECF Nos. 46 anc all attachments) under seal. Such motion must be specify with precision the proposed bases for sealing or n ular redactions, with citations to relevant authority. Any proposed redactions must be narrowly tailored to serve invoked. The parties shall also file proposed redacted versions of the subject documents (including all on the public docket. The motion shall state whether there are any objections to proposals for sealing an

motions shall be filed no later than October 30, 2025. such motion is filed by the date, the Court will Nos. 45 and 46 shall be unsealed. If any such motion is filed, the Court will maintain those documents unde seal pending resolution of the motion. of Court is respectfully directed to terminate ECF No. 45. RDERED.