Judge: Christopher K. Lui, Case: 20STCV35441, Date: 2022-08-18 Tentative Ruling



Case Number: 20STCV35441    Hearing Date: August 18, 2022    Dept: 76


            Plaintiff alleges that, without compensating or crediting her, Defendants misappropriated, used and exploited Plaintiff’s protected work, ideas, and concepts for an innovative treatment and script to produce their own movie for profit.

Defendants Warner Bros. Entertainment Inc. and New Line Productions, Inc. move to seal documents lodged conditionally under seal.

Defendants Warner Bros. Entertainment Inc., New Line Productions, Inc., Melissa McCarthy, Benjamin Scott Falcone, and On the Day Productions, LLC move for summary judgment, or in the alternative, summary adjudication, as to the Complaint. 

Defendants Ratpac Entertainment, LLC and Brett Ratner move for summary judgment or, in the alternative, summary adjudication, as to the Complaint.

THE COURT HAS NOT PREPARED A TENTATIVE RULING ON THE RATPAC DEFENDANTS' MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION

TENTATIVE RULING

            Defendants Warner Bros. Entertainment, Inc. and New Line Productions, Inc.’s motion to seal is DENIED. Within 10 days of this order, Defendants are ordered to either consent to the subject document being filed unsealed, or may in the alternative, file a version of the exhibit which redacts information that Defendants deem to be too sensitive for public disclosure. (Cal. Rules of Court 2.551(b)(6).)  Otherwise, the entire lodged record will be returned to Defendants and will not be considered by the Court.

Defendants Warner Bros. Entertainment Inc., New Line Productions, Inc., Melissa McCarthy, Benjamin Scott Falcone, and On the Day Productions, LLC’s motion for summary judgment is CONTINUED to September 15, 2022 at 8:30 AM. Defendants are to publicly file properly redacted versions of their notion of motion / memorandum of points and authorities, separate statement, and compendium of evidence by September 1, 2022 (which is the date on which Defendants Warner Bros., et al.’s motion to seal is to be heard). Plaintiff is also to file an unredacted version of the Evidence In Support of the Opposition by September 1, 2022.

ANALYSIS

 

Motion To Seal

 

Defendants Warner Bros. Entertainment Inc. and New Line Productions, Inc. move to seal the following document lodged conditionally under seal: The Slate Co-Financing and Distribution Agreement dated September 30, 2013 (attached as Exhibit A to the Declaration of Brett Ratner, and as Exhibit A to the Declaration of Wayne M. Smith in the Compendium of Evidence), which was lodged in support of Defendant Brett Ratner and RatPac Entertainment LLC’s motion for summary judgment or, in the alternative, summary adjudication.

 

A motion seeking an order sealing the record must be accompanied by “a declaration containing facts sufficient to justify the sealing.” (Cal. Rules of Court 2.551(b)(1) [bold emphasis and underlining added].)  Per CRC Rule 2.550(d), a court may order that a record be filed under seal “only if it expressly finds facts that establish” all of the following:

 

 (1) There exists an overriding interest that overcomes the right of public access to the record;

 

 (2) The overriding interest supports sealing the record;

 

 (3) A substantial probability exists that the overriding interest will be prejudiced if the record is not sealed;

 

 (4) The proposed sealing is narrowly tailored; and

 

 (5) No less restrictive means exist to achieve the overriding interest.

           

     (Cal. Rules of Court, 2.550(d)[bold emphasis added].)

 

            CRC Rule 2.550(e) provides:

 

            (1) An order sealing the record must:

(A)   Specifically state the facts that support the findings;

(B)   Direct the sealing of only those documents and pages, or, if reasonably practicable, portions of those documents and pages, that contain the material that needs to be placed under seal. All other portions of each document or page must be included in the public file.

 

[Cal. Rules of Court 2.550(e).]

 

“A request to seal a document must be filed publicly and separately from the object of the request. It must be supported by a factual declaration or affidavit explaining the particular needs of the case.” (In re Marriage of Lechowick (1998) 65 Cal.App.4th 1406, 1416 [bold emphasis and underlining added].)

 

The fact that the documents sought to be sealed were designed confidential subject to protective order is, by itself, insufficient to justify sealing.

 

Unless confidentiality is required by law, court records are presumed to be open.”  (Cal. Rules of Court 2.550(c)[bold emphasis and underlining added]).  The trial court cannot rely solely on an agreement or stipulation of the parties as the basis for permitting records to be filed under seal. (Citations omitted.)” (Savaglio v. Wal-Mart Stores, Inc. (2007) 149 Cal.App.4th 588, 600 [bold emphasis and underlining added].)

 

Accordingly, moving party must demonstrate by way of a factual declaration or affidavit that all of the CRC Rule 2.550(d) requirements for sealing have been met.

 

¿         CRC Rule 2.550(d) factors:

 

 (1) There exists an overriding interest that overcomes the right of public access to the record:

 

In terms of the overriding interest requirement of a closure or sealing order, NBC Subsidiary identifies two separate elements. The first element requires the identification of an overriding interest. (NBC Subsidiary (KNBC-TV), Inc. v. Superior Court, supra, 20 Cal.4th at pp. 1217–1218; see In re Providian Credit Card Cases, supra, 96 Cal.App.4th at p. 298, fn. 3.) Defendant has identified such a potential overriding interest—a binding contractual agreement not to disclose.

. . .

 

We agree with defendant that its contractual obligation not to disclose can constitute an overriding interest within the meaning of rule 243.1(d). (Publicker Industries, Inc. v. Cohen, supra, 733 F.2d at p. 1073; NBC Subsidiary (KNBC-TV), Inc. v. Superior Court, supra, 20 Cal.4th at p. 1222, fn. 46.)

 

(Universal City Studios, Inc. v. Superior Court (2003) 110 Cal.App.4th 1273, 1283.)

 

            Here, Defendants identify the financing agreement having been designated as “Confidential” under the Stipulated Protective Order signed by the Court on March 10, 2021. Defendants argue that the Slate Co-Financing and Distribution Agreement dated September 30, 2013 contains sensitive, proprietary information pertaining to WBEI’s and New Line’s means of conducting business and non-public financial data that has been kept, and should continue to be kept, confidential.

 

                 Defendants’ interest in keeping the information confidential constitutes an overriding interest the right of public access to the record.

 

This requirement is satisfied.

 

 (2) The overriding interest supports sealing the record;

 

            Moving party does not explain why the overriding interest supports sealing, as opposed to redaction, of the record.

 

            This requirement is not satisfied.

 

 (3) A substantial probability exists that the overriding interest will be prejudiced if the record is not sealed;

 

            Although moving party has identified an overriding interest, that, by itself, is insufficient to justify a sealing order.

We have been unable to find any appellate court decision which construes Publicker to permit sealing of court documents merely upon the agreement of the parties without a specific showing of serious injury. We therefore, with respect, reject defendant’s broad reading of the citation to Publicker in footnote 46 of NBC Subsidiary.

. . . [O]nce it is established there is a potential overriding interest, the party seeking closure or sealing must prove prejudice to that interest is substantially probable. ( NBC Subsidiary (KNBC-TV), Inc. v. Superior Court, supra, 20 Cal.4th at p. 1222.)

In terms of the overriding interest requirement of a closure or sealing order, NBC Subsidiary identifies two separate elements. The first element requires the identification of an overriding interest. ( NBC Subsidiary (KNBC-TV), Inc. v. Superior Court, supra, 20 Cal.4th at pp. 1217–1218; see In re Providian Credit Card Cases, supra, 96 Cal.App.4th at p. 298, fn. 3.) Defendant has identified such a potential overriding interest—a binding contractual agreement not to disclose. The second element of the overriding interest analysis is there must be a substantial probability that it will be prejudiced absent closure or sealing. ( NBC Subsidiary (KNBC-TV), Inc. v. Superior Court, supra, 20 Cal.4th at p. 1218; Pack v. Kings County Human Services Agency (2001) 89 Cal.App.4th 821, 832 [107 Cal. Rptr. 2d 594].) As we will note, defendant has not shown a substantial probability any such interest in the present case will be prejudiced—the second element of overriding interest analysis identified in NBC Subsidiary. This analysis has now been promulgated by the Judicial Council as one of the findings that must be returned before a sealing order can be entered. (Rule 243.1(d)(3) [“A substantial probability exists that the overriding interest will be prejudiced if the record is not sealed ….”].)

 

(Universal City Studios, Inc., supra, 110 Cal.App.4th at 1282-83 [bold emphasis and underlining added].)

 

Moving party has not presented admissible evidence that the overriding interest will be prejudiced if the record is not sealed.

 

In delineating the injury to be prevented, specificity is essential. [Citation.] Broad allegations of harm, bereft of specific examples or articulated reasoning, are insufficient.” ( In re Cendant Corp., supra, 260 F.3d at p. 194 .) We have been unable to find any appellate court decision which construes Publicker to permit sealing of court documents merely upon the agreement of the parties without a specific showing of serious injury. We therefore, with respect, reject defendant’s broad reading of the citation to Publicker in footnote 46 of NBC Subsidiary.

(Universal City Studios, Inc., supra, 110 Cal.App.4th at 1280-82 [bold emphasis and underlining added].)

 

Indeed, the barebones Declaration of Arwen R. Johnson falls woefully short of meeting the above evidentiary standard.

 

This requirement is not satisfied.      

 

             (4) The proposed sealing is narrowly tailored;

 

            The proposed sealing does not appear to be narrowly tailored, as the entire exhibit is sought to be sealed, rather than portions thereof.

 

            This requirement is not satisfied.

 

 (5) No less restrictive means exist to achieve the overriding interest.

           

Moving party has not addressed why redaction would be insufficient to achieve the overriding interest.

 

This requirement is not satisfied.

 

            As such, the motion to seal is DENIED. Within 10 days of this order, Defendants are ordered to either consent to the subject document being filed unsealed, or in the alternative, may file a version of the exhibit which redacts information that Defendants deem to be too sensitive for public disclosure. (Cal,. Rules of Court 2.551(b)(6).) Otherwise, the entire lodged record will be returned to Defendants and will not be considered by the Court.

 

Melissa McCarthy, Benjamin Scott Falcone, and On the Day Productions, LLC’s Motion For Summary Judgment

 

            On June 3, 2022, Defendants Warner Bros. Entertainment Inc., New Line Productions, Inc., Melissa McCarthy, Benjamin Scott Falcone, and On the Day Productions, LLC filed a Notice of Motion for Summary Judgment/Summary Adjudication, which did not contain ANY information, but simply stated:

 

REDACTED VERSION OF DOCUMENT CONDITIONALLY

FILED UNDER SEAL

 

COMPLETE DOCUMENT SOUGHT TO BE SEALED

 

This also applies to the Separate Statement and Compendium of Evidence.

 

This form of submitting papers to the Court is unacceptable, as there is no indication in the public record as to ANY argument or evidence which the Court would consider in ruling on this motion.  In NBC Subsidiary, the California Supreme Court approvingly cited numerous cases for the proposition that there is a First Amendment right of access to “civil litigation documents filed in court as a basis for adjudication.”  (NBC Subsidiary, supra, 20 Cal.4th 1178 at 1208 n.25.)  The Court is unaware of any scenario that would justify the Court considering a motion composed of non-public arguments, based entirely on non-public undisputed facts, supported by non-public evidence.  Assuming such a scenario even exists, the Warner Bros. defendants have not met the considerable burden of showing that it exists here.

 

            The Court also notes that the procedure followed by the Warner Bros. defendants does not follow Rule of Court 2.551.  The motion to seal did not justify, much less address, a basis for sealing the entire notice of motion and memorandum of points and authorities, yet the entire set of documents was filed conditionally under seal.  

 

            Likewise, Plaintiff’s Evidence In Support of the Opposition does not contain any information, and simply states that the complete document is sought to be sealed. However, Plaintiff did not file a motion to seal its opposition.

 

            As such, the hearing on Defendants Warner Bros. Entertainment Inc., New Line Productions, Inc., Melissa McCarthy, Benjamin Scott Falcone, and On the Day Productions, LLC’ s motion for summary judgment/summary adjudication is CONTINUED to September 15, 2022 at 8:30 AM.  Defendants are to publicly file properly redacted versions of their notion of motion / memorandum of points and authorities, separate statement, and compendium of evidence by September 1, 2022 (which is the date on which Defendants Warner Bros., et al’s motion to seal is to be heard). Plaintiff is also to file an unredacted version of the Evidence In Support of the Opposition by September 1, 2022, as no motion to seal these documents has been filed.