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Home Court filings Beringer Commerce, Inc. v. FIN Cap, Inc. Memorandum in Support regarding 6 Motion to Seal Document 5 Proposed Sealed — Beringer Commerce, Inc. v. FIN Cap, Inc. (Dkt. 7, E.D.N.C. No. 5:21-cv-00251)

Court filing

Memorandum in Support regarding 6 Motion to Seal Document 5 Proposed Sealed — Beringer Commerce, Inc. v. FIN Cap, Inc. (Dkt. 7, E.D.N.C. No. 5:21-cv-00251)

Filed June 10, 2021 in Beringer Commerce, Inc. v. FIN Cap, Inc.; one of 94 filings from this case.

Record facts

CourtU.S. District Court for the Eastern District of North Carolina
Filed2021-06-10

U.S. District Court for the Eastern District of North Carolina · No. 5:21-cv-00251-BO · Doc. 7 · 2021-06-10 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT  
FOR THE EASTERN DISTRICT OF NORTH CAROLINA 
WESTERN DIVISION 
Civil Action No. _______________________ 
BERINGER COMMERCE, INC. d/b/a 
BLUE ACORN iCi,  
Plaintiff, 
v. 
FIN CAP, INC. d/b/a 
“BLUEACORN.CO,” BLUE ACORN 
PPP, LLC, BLUE OAK FOREST, LLC, 
MICHAEL S. COTA, JIMMY FLORES, 
STEPHANIE HOCKRIDGE REIS, and 
NATHAN REIS, 
Defendants. 
PLAINTIFF’S MEMORANDUM IN 
SUPPORT OF MOTION FOR LEAVE TO 
FILE UNDER TO SEAL 
NOW COMES Plaintiff BERINGER COMMERCE, INC. d/b/a BLUE ACORN iCi, by 
and through undersigned counsel, and submits this Memorandum in Support of its Motion for 
Leave to File Under Seal. In support of this Motion, Plaintiff states as follows:  
1.
Plaintiff seeks to file Exhibits F, J, L, and N to its Verified Complaint (the
“Exhibits”) under seal, each of which have been contemporaneously filed as proposed sealed 
documents. 
2.
The Exhibits consist of consumer complaints submitted to Plaintiff regarding
services provided by Defendants in connection with their business which purports to assist small 
businesses and contractors with obtaining loans through the federal Paycheck Protection Act 
(“PPP”). As such, the Exhibits contain PPP application materials discussing, among other things, 
each applicant’s total monthly payroll, and other sensitive financial and business information. 
5:21-cv-00251-BO
Case 5:21-cv-00251-BO     Document 7     Filed 06/10/21     Page 1 of 5

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3. 
The consumers who submitted the complaints contained in the Exhibits are not 
parties to the instant action. 
4. 
Before sealing any documents, courts must determine whether the public’s right of 
access arises from the common law or the First Amendment. Stone v. Univ. of Md., 855 F.2d 178, 
180 (4th Cir. 1988). “The common law presumption in favor of access attaches to all judicial 
records and documents, whereas First Amendment protection is extended to only certain judicial 
records and documents, for example, those filed in connection with a summary judgment motion.” 
Quinn v. Town of Fremont, No. 5:12-CV-742-D, 2013 WL 2285347, at *1 (E.D.N.C. May 23, 
2013) (unpublished). Where the document sought to be sealed is a pleading, the public’s right of 
access arises from the First Amendment. Id. (citing Rushford v. New Yorker Magazine, 846 F.2d 
249, 252–53 (4th Cir. 1988)). 
5. 
“Under this First Amendment standard, the movant must demonstrate that the 
denial of access is necessitated by a compelling government interest or non-governmental interest 
that implicates similar ‘higher values.’” Nielson v. Portfolio Recovery Assocs., LLC, No. CV 2:18-
1610-RMG, 2019 WL 2513722, at *2 (D.S.C. June 18, 2019) (unpublished) (citing Press-Enter. 
Co. v. Riverside, 464 U.S. 501, 510 (1984)). “Such private interests outweigh the First Amendment 
presumption of access ‘only in certain circumstances’ that include a criminal defendant’s Sixth 
Amendment right to a fair trial, privacy interests of non-parties, trade secrets, attorney-client 
relationships, and contractual non-disclosure provisions.” Id. (citing Companion Prop. & Cas. Ins. 
Co. v. Wood, No. 3:14-cv-03719-CMC, 2017 WL 279767, at *2 (D.S.C. Jan. 23, 2017) 
(unpublished)) (emphasis added). 
6. 
“When considering a motion to seal, district courts must give the public notice of 
the request to seal and a reasonable opportunity to challenge the request.” Mears v. Atl. Se. Airlines, 
Case 5:21-cv-00251-BO     Document 7     Filed 06/10/21     Page 2 of 5

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Inc., No. 5:12-CV-613-F, 2014 WL 5018907, at *2 (E.D.N.C. Oct. 7, 2014) (unpublished) (citing 
In re Knight Publ’g, 743 F.2d 231, 235 (4th Cir.1984)). “The filing of a litigant’s motion to seal  
. . . is sufficient to provide public notice and opportunity to challenge the request to seal.” Id. 
7. 
“The court must also consider less drastic alternatives to sealing, if any.” Id. 
8. 
Here, the public’s right of access to the Exhibits arises under the First Amendment. 
However, the materials contained in the Exhibits concern “the privacy interests of non-parties,” 
which constitutes one of the limited circumstances sufficient to overcome the public’s First 
Amendment right of access. See Nielson, 2019 WL 2513722, at *2. 
9. 
The Exhibits have been redacted pursuant to Federal Rule of Civil Procedure 5.2, 
which requires redaction of certain information such as social security numbers and financial 
account numbers. Even with these redactions applied, however, the Exhibits still contain sensitive 
and private information related to operation of businesses owned by non-parties to the instant 
lawsuit. Additionally, further redactions would render the Exhibits cumbersome and difficult to 
use for the parties and the Court. As a result, there are no viable alternatives to sealing the Exhibits. 
See Collins v. Chem. Coatings, Inc., No. 5:07CV116, 2008 WL 5105277, at *2 (W.D.N.C. Dec. 
1, 2008) (unpublished) (determining that no alternatives existed to sealing and stating that “sealing 
is necessary to protect sensitive personal health information and identifiers from becoming public 
records and redacting the pleadings would result in much of the material being useless.”). 
10. 
The filing of the instant motion gives the public adequate “notice and opportunity 
to challenge the request to seal.” Mears, 2014 WL 5018907, at *2. 
For the reasons stated above, Plaintiff requests that this Court grant leave to file Exhibits 
F, J, L, and N to its Verified Complaint under seal. 
 
 
Case 5:21-cv-00251-BO     Document 7     Filed 06/10/21     Page 3 of 5

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RESPECTFULLY SUBMITTED this 10th day of June, 2021. 
 
/s/ Beth A. Stanfield  
 
 
 
Beth A. Stanfield (N.C. State Bar No. 36296) 
Thomas Babel (N.C. State Bar No. 35004) 
Laura K. Greene (N.C. State Bar No. 47771) 
FORREST FIRM, P.C. 
105 Grace Street, Suite 101 
Wilmington, NC 28401 
T/F: (336) 275-6344 
Beth.stanfield@forrestfirm.com  
thomas.babel@forrestfirm.com  
katie.greene@forrestfirm.com  
 
Attorneys for Plaintiff 
 
 
Case 5:21-cv-00251-BO     Document 7     Filed 06/10/21     Page 4 of 5

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CERTIFICATE OF SERVICE 
 
The undersigned does hereby certify that a copy of the foregoing PLAINTIFF’S 
MEMORANDUM IN SUPPORT OF MOTION FOR LEAVE TO FILE UNDER TO SEAL 
has been filed with the Clerk for the United States District Court, Eastern District of North 
Carolina, using the electronic filing system of the Court and that the foregoing was served upon 
the following persons by depositing a copy of the same in the United States Mail in an envelope, 
postage prepaid, addressed as follow: 
 By placing a copy, contained in a first-class, postage paid wrapper, into a depository 
under the exclusive custody of the United States Postage Service, addressed to the 
parties as indicated below: 
 
Fin Cap, Inc. d/b/a "Blueacorn.co" 
c/o Legalinc Corporate Services Inc. 
5830 E 2nd St Ste 8 
Casper, WY 82609 
Blue Oak Forest, LLC 
c/o Delaware Registered Agents & 
Incorporators, LLC 
19 Kris Court 
Newark, DE 19702 
 
Blue Acorn PPP, LLC 
c/o Radix Law, PLC, Registered Agent 
Jeff Meyerson 
15205 N. Kierland Blvd, Ste 200,  
Scottsdale, AZ 85254 
 
Michael S. Cota 
2138 S. Valle Verde Cir 
Mesa, AZ 85209 
Stephanie Hockridge Reis 
4747 N. Scottsdale Road, Unit C 
Scottsdale, AZ 85251 
 
Nathan Reis 
4747 N. Scottsdale Road, Unit C 
Scottsdale, AZ 85251 
James M. Flores 
7833 E. Harvard Street 
Scottsdale, AZ 85257 
 
 
 
This the 10th day of June, 2021. 
 
 
 
 
 
 
 
 
/s/ Beth A. Stanfield  
 
 
 
 
 
 
 
 
Beth A. Stanfield 
 
 
 
 
 
 
 
 
Thomas Babel 
 
 
 
 
 
 
 
 
Laura K. Greene 
 
 
 
 
 
 
 
 
Attorneys for Plaintiff 
Case 5:21-cv-00251-BO     Document 7     Filed 06/10/21     Page 5 of 5

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