Judge: Teresa A. Beaudet, Case: 22STCV30776, Date: 2025-06-12 Tentative Ruling

Case Number: 22STCV30776    Hearing Date: June 12, 2025    Dept: 50

Superior Court of California

County of Los Angeles

Department 50

            Background

On September 20, 2022, Plaintiffs Jane Doe 2 (A.T.); Jane Doe 3 (A.T.); Jane Doe 4 (G.T.), minors by and through their Guardian Ad Litem Jane Doe 1 (A.T.) (collectively, “Plaintiffs”) filed a Complaint against Defendants County of Los Angeles (“County”), Los Angeles County Sheriff’s Department (“LASD”) (collectively, “Defendants”), and DOES 1 through 20, inclusive for: (1) personal Injury: Sexual Abuse of a Minor; (2) Negligent Infliction of Emotional Distress; and (3) Negligent Supervision, Training, Review, and Retention.

Plaintiffs now move for an order directing the “sealing via redaction of confidential information from the following documents: (1) Petition for Approval of Compromise for Jane Doe 2 (A.T.); (2) Order Approving Compromise for Jane Doe 2 (A.T.); (3) Order to Deposit Funds in Blocked Account for Jane Doe 2 (A.T.); (4) Petition for Approval of Compromise for Jane Doe 3 (A.T.); (5) Order Approving Compromise for Jane Doe 3 (A.T.); (6) Order to Deposit Funds in Blocked Account for Jane Doe 3 (A.T.); (7) Petition for Approval of Compromise for Jane Doe 4 (G.T.); Order Approving Compromise for Jane Doe 4 (G.T.); (9) Order to Deposit Funds in Blocked Account for Jane Doe 4 (G.T.); and (10) any executed Order(s) entered by the Court following the hearing on the compromise petitions for the Plaintiffs (collectively referred to as “Compromise Petition Documents”).” (Mot. at 1:28-2:9.) Plaintiffs also request the hearing on the compromise petitions set for June 20, 2025 be closed to the public or alternatively, all issues with counsel be discussed via sidebar or in chambers. (Id. at 2:10-12.) The motion is unopposed.

            Discussion

Generally, court records are presumed to be open unless confidentiality is required by law. (Cal. Rules of Court, Rule 2.550, subd. (c).) If the presumption of access applies, the court may order that a record be filed under seal “if it expressly finds facts that establish: (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, Rule 2.550, subd. (d).)

Plaintiffs seek to seal the Compromise Petition Documents via redaction because they reference Plaintiffs’ identities and other personally identifiable information, the settlement amounts and proposed amounts to be paid, how the settlement amounts will be invested, and Plaintiffs counsel’s percentage-based fee. The Compromise Petition Documents were lodged with the Court on May 15, 2025 in compliance with California Rules of Court, Rule 2.551, subdivision (b)(4). The Court has reviewed the Compromise Petition Documents.

With respect to the first and second elements of California Rules of Court, Rule 2.550, subdivision (d), Plaintiffs contend protecting their identities is critical given the nature of the abuse allegations and the publicity of the criminal case. Specifically, Plaintiffs are survivors of sexual abuse by Sean Jerome Essex, a former LASD deputy and the criminal case against Mr. Essex received extensive media attention. (Mot. at 6:25-28.) As such, Plaintiffs argue disclosure of their identities to the public would cause renewed emotional harm and further public scrutiny. (Id. at 6:28-7:2.) Furthermore, Plaintiffs assert they have a privacy interest in protecting the disclosure of the financial recovery in this case as they are minors and such disclosure could potentially expose them to exploitation by third parties. (Id. at 7:8-11.) Moreover, Plaintiffs’ contend there is no public interest in their personally identifiable information and financial recovery because this information is not necessary for the adjudication of their claims set forth in this lawsuit. (Id. at 7:21-23.) Likewise, there is a strong policy favoring settlement and disclosing settlement amounts would undermine such policy. Here, the Compromise Petition Documents contain information detailing the full names of the Plaintiffs, the nature of the allegations, injuries Plaintiffs have suffered as a result of the abuse allegations, and how the settlement amounts are to be distributed for the Plaintiffs overtime. Thus, the Court finds that the first and second elements have been met.

With respect to the third element of California Rules of Court, Rule 2.550, subdivision (d), Plaintiffs contend there is a substantial probability that Plaintiffs’ overriding interest in the nondisclosure of their personally identifiable information and financial recovery would be prejudiced without sealing. As discussed above, this case involved sexual abuse allegations and highly publicized criminal proceedings concerning these allegations was adjudicated. Also, Plaintiffs are minors whose financial recovery is intended to provide for long-term living and rehabilitation needs. (Mot. at 7:13-14.) As such, the Court agrees there is a substantial probability that the public disclosure of their personally identifiable information and financial recovery would prejudice them. Thus, the Court finds that the third element has also been met.

As to the fourth element of California Rules of Court, Rule 2.550, subdivision (d), Plaintiffs assert the proposed sealing is narrowly tailored because it only seeks to redact from the Compromise Petition Documents the Plaintiffs’ identities and other personally identifiable information, the settlement amounts and proposed amounts to be paid, how the settlement amounts will be invested, and Plaintiffs counsel’s percentage-based fee not the entire record. (Mot. at 8:10-13.) Similarly, the discussion of this information would be permitted via sidebar out of earshot of the public and/or chambers. (Id. at 8:15-16.) Although the Compromise Petition Documents mainly refer to the Plaintiffs’ by their abbreviated pseudonyms, there are attachments and exhibits that contain their full names, date of births, ages, and residential addresses. Therefore, redaction of their personally identifiable information is appropriate as it allows the Compromise Petitions to go forth while protecting the minor Plaintiffs. Also, redacting the settlement amounts and Plaintiffs’ counsel’s fee recovery would protect Plaintiffs from being potentially taken advantage of by third parties. Thus, the Court finds that the fourth element has been met as well.

As to the fifth element of California Rules of Court, Rule 2.550, subdivision (d), Plaintiffs contend this is the least restrictive means of preserving the confidentiality of the Plaintiffs’ privacy interests because it through redaction of certain aspects of the Compromise Petition Documents. (Mot. at 8:19-22.) Here, the parties in this case have settled and are required to file Petitions for Minor Compromise. As mentioned above, this case involved minor children and highly sensitive allegations surrounding sexual abuse. Redacting the personally identifiable information and financial recovery of the Plaintiffs is the best way to comply with the requirements for filing a Petition for Minor Compromise while protecting the privacy interests of the Plaintiffs. Thus, the Court finds that the fifth element has been met.

Accordingly, the Court finds that Plaintiffs have shown that good cause exists to seal the Compromise Petition Documents via redaction as proposed herein.

Closing Proceedings

To the extent Plaintiffs also request a closed portion of the hearing on the compromise petitions set for June 20, 2025, at 10:00 a.m., the Court finds that closure is appropriate when discussing the Plaintiffs’ personally identifiable information and financial recovery as set forth above. (See NBC Subsidiary (KNBC-TV), Inc. v. Superior Court (1999) 20 Cal.4th 1178, 1226 stating [“The need to comply with the requirements of the First Amendment right of access may impose some burdens on trial courts. But courts can and should minimize such inconveniences by proposing to close proceedings only in the rarest of circumstances.”].)

Conclusion

Based on the foregoing, Plaintiffs’ Motion to Seal is GRANTED. Pursuant to California Rules of Court, Rule 2.551, subdivision (e), the Court directs the clerk to file this order, maintain the Exhibits ordered sealed in a secure manner, and clearly identify the Exhibits as sealed by this Order.

Plaintiffs’ are ordered to provide notice of this ruling.

DATED:  June 12, 2025                                

________________________________

Hon. Teresa A. Beaudet

Judge, Los Angeles Superior Court