Whittaker v. MHR Fund Management LLC

CourtDistrict Court, S.D. New York
DecidedSeptember 28, 2021
Docket1:20-cv-07599
StatusUnknown

This text of Whittaker v. MHR Fund Management LLC (Whittaker v. MHR Fund Management LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Whittaker v. MHR Fund Management LLC, (S.D.N.Y. 2021).

Opinion

USDC SDNY UNITED STATES DISTRICT COURT DOCUMENT SOUTHERN DISTRICT OF NEW YORK ELECTRONICALLY FILED KEITH WHITTAKER, DOC# DATE FILED: 9/30/2021 Petitioner, -against- MHR FUND MANAGEMENT LLC, MHR 20 Civ. 7599 (AT) INSTITUTIONAL ADVISORS II LLC, AND MHR INSTITUTIONAL ADVISORS HI LLC, ORDER Respondents. ANALISA TORRES, District Judge: Petitioner, Keith Whittaker, brings this proceeding under the Federal Arbitration Act (“FAA”), 9 U.S.C. §§ 10-11, to vacate or modify a May 1, 2020 arbitration award, as modified on June 19, 2020 (the “PFA”), and a June 21, 2020 supplemental award addressing both parties’ motions for sanctions (the “Sanctions Award”), issued in an arbitration with Respondents MHR Fund Management LLC, MHR Institutional Advisors I] LLC, and MHR Institutional Advisors IH LLC, (collectively “MHR”). Pet., ECF No. 14. MHR brought two motions: (1) to confirm the PFA and the Sanctions Award, ECF No. 38; and (2) to confirm the final award issued on November 3, 2020 (the “Final Award” and collectively with the PFA and the Sanctions Award, the “Awards”), ECF No. 44. The parties have since filed five motions seeking leave to redact or seal in full documents submitted in connection with their briefing in this case. ECF Nos. 35, 41, 47, 54, 60. BACKGROUND'! Petitioner commenced this proceeding on September 16, 2020, seeking to vacate or modify the PFA and Sanctions Awards pursuant to the Federal Arbitration Act, 9 U.S.C. §§ 10-

' The Court assumes familiarity with the factual and procedural background of this action, as set forth in its order on the motions at issue, ECF No. 62.

11. Pet. at 1, 11. The same day, the Honorable Jed S. Rakoff granted Petitioner’s motion to file the petition under seal, but ordered that Petitioner’s filings remain under seal only until September 23, 2020. ECF No. 12. On September 24, 2020, this Court denied the parties’ separate requests to seal the entire proceeding, but found that sealing might be justified for

certain exhibits to the petition. ECF No. 5. The Court, therefore, directed the parties to confer and narrow their requests for sealing. Id. On October 1, 2020, MHR filed a letter motion seeking redactions to nineteen exhibits attached to Petitioner’s memorandum of law in support of his petition (the “October 1 Request”). ECF No. 36 at 1–2. MHR further requested that eight other exhibits to the petition remain sealed in their entirety. Id. On October 6, 2020, Petitioner filed a response agreeing to redactions to only two documents that contained personal and financial information of non-parties but otherwise arguing that the other documents MHR sought to seal “do not meet the Court’s criteria for sealing.” ECF No. 37 at 1 n.1. On October 30, 2020, MHR moved to confirm the PFA and Sanctions Award. ECF No.

38. MHR also requested leave to seal six exhibits appended to its memorandum of law (the “October 30 Request”). ECF No. 41. MHR further sought to redact portions of the memorandum which cited these exhibits. Id. On November 13, 2020, MHR filed a supplemental motion to confirm the Final Award. ECF No. 44. On November 20, 2020, Petitioner requested leave to seal nine exhibits attached to papers submitted in further support of the petition and in opposition to MHR’s motion (the “November 20 Request”). ECF No. 47. On December 11, 2020, MHR sought leave to partially seal the reply memorandum submitted on that date (the “December 11 Request”). ECF No. 54. The parties filed their respective Rule 56.1 statements and counter-statements on December 22, 2020. ECF Nos. 56–59, 61. MHR simultaneously requested redaction of portions of its counter-statement to Petitioner’s Rule 56.1 statement (the “December 22 Request”). ECF No. 60.

The Court addresses each request in turn. DISCUSSION I. Legal Standard There is a presumptive right of access to judicial documents rooted in both common law and the First Amendment. United States v. Erie Cnty., 763 F.3d 235, 238–39 (2d Cir. 2014). Under the First Amendment, the Second Circuit has clarified that “documents may be sealed if specific, on the record findings are made demonstrating that closure is essential to preserve higher values and is narrowly tailored to serve that interest.” Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006) (citation, alterations, and quotation marks omitted). However, “[b]road and general findings by the trial court . . . are not sufficient to

justify closure.” Id. (citation omitted). Under the common law, courts in this Circuit follow a three-step process for determining whether documents should be sealed or redacted. First, a court must determine whether the presumption of access attaches. A presumption of access attaches to any item that constitutes a “judicial document”—i.e., an “item . . . relevant to the performance of the judicial function and useful in the judicial process[.]” Id. at 119 (citation omitted). Second, a court must determine the weight of the presumption of access. “[T]he weight to be given the presumption of access must be governed by the role of the material at issue in the exercise of Article III judicial power, and the resultant value of such information to those monitoring the federal courts.” Id. (alteration in original) (citation omitted). “Generally, the information will fall somewhere on a continuum from matters that directly affect an adjudication to matters that come within a court’s purview solely to insure their irrelevance.” Id. (citation omitted). Petitions to confirm, vacate, or modify arbitration awards, their memoranda of law,

and supporting documents, including exhibits in support—such as those at issue here—are “judicial documents that directly affect[] the Court’s adjudication” of the petition. Alexandria Real Est. Equities, Inc. v. Fair, No. 11 Civ. 3694, 2011 WL 6015646, at *2 (S.D.N.Y. Nov. 30, 2011) (alteration in original) (citation omitted). They are, therefore, subject to a “strong presumption of public access.” Susquehanna Int’l Grp. Ltd. v. Hibernia Exp. (Ireland) Ltd., No. 21 Civ. 207, 2021 WL 3540221 at *3 (S.D.N.Y. Aug. 11, 2021). Finally, a court must “balance competing considerations against” the weight of the presumption. Lugosch, 435 F.3d at 120 (citation omitted). Such competing considerations can include, for instance, third-parties’ privacy interests against disclosure, or the protection of sensitive, competitive or proprietary business information. United States v. Amodeo, 71 F.3d

1044, 1050–51 (2d Cir. 1995). Accordingly, courts have allowed redactions of third-party employees’ compensation information, Valassis Commc’ns Inc. v. News Corp., No. 17 Civ. 7378, 2020 WL 2190708, at *4 (S.D.N.Y. May 5, 2020), investor identities, particularly where “there is no evidence that the identities of investors directly affect the adjudication,” Caxton Int’l Ltd. v. Rsrv. Int’l Liquidity Fund, Ltd., No. 09 Civ. 782, 2009 WL 2365246, at *7 (S.D.N.Y. Jul. 30, 2009) (citation and quotation marks omitted), and information going to a company’s “internal analyses [and] business strategies,” SEC v. Telegram Grp. Inc., No. 19 Civ. 9439, 2020 WL 3264264, at *3 (S.D.N.Y. June 17, 2020). To rebut the presumption of public access, merely “conclusory statements that documents contain confidential business information” are insufficient to justify sealing. United States v. Wells Fargo Bank, No. 12 Civ. 7527, 2015 WL 3999074, at *4 (S.D.N.Y. June 30, 2015). Rather, the moving party must make a “particular and specific demonstration of fact showing

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Related

United States v. Amodeo
71 F.3d 1044 (Second Circuit, 1995)
Lugosch v. Pyramid Co. of Onondaga
435 F.3d 110 (Second Circuit, 2006)
United States v. Erie County
763 F.3d 235 (Second Circuit, 2014)
Brown v. Maxwell Dershowitz v. Giuffre
929 F.3d 41 (Second Circuit, 2019)
Bernsten v. O'Reilly
307 F. Supp. 3d 161 (S.D. Illinois, 2018)

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Bluebook (online)
Whittaker v. MHR Fund Management LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/whittaker-v-mhr-fund-management-llc-nysd-2021.