Plaintiff Youras Ziankovich respectfully moves the Court for an order requiring redaction of, or in the alternative sealing of, Exhibit C to the Second Declaration of Andrea Macchiavello (Doc. 17-1). In support, Plaintiff states as follows:
I. NATURE OF THE REQUEST
Exhibit C contains a detailed list of Plaintiff’s financial transactions, including the names and identifying information of third-party recipients. Defendant could have submitted a redacted exhibit but chose not to do so.
This information is not necessary to resolve Defendant’s Motion to Compel Arbitration and implicates significant privacy interests of non-parties.
II. LEGAL STANDARD
Judicial records are subject to a common-law right of public access. However, that right is not absolute.
Courts must balance the public’s interest in access against competing interests, including privacy rights and the risk of harm from disclosure.
Sealing or redaction is appropriate where the information at issue is sensitive, involves non-parties, or is not necessary to the adjudication of the motion before the Court.
III. ARGUMENT
A. The Public Interest in Access Is Minimal
Exhibit C does not bear on the legal issue before the Court: whether a valid arbitration agreement exists.
Defendant relies on Exhibit C only to show that Plaintiff initiated certain transactions. The identities of third-party recipients are not relevant to contract formation, assent, or arbitrability.
Because the disclosed information is not material to the Court’s analysis, the public interest in access is minimal.
B. The Privacy Interests of Non-Parties Are Significant
Exhibit C discloses sensitive financial information of individuals who are not parties to this litigation.
Courts consistently recognize that non-party privacy interests weigh heavily against public disclosure, particularly where the information involves personal financial transactions.
The individuals identified in Exhibit C have no ability to protect their interests in this proceeding, further strengthening the need for protection.
C. Disclosure Creates a Risk of Harm
The transactions reflected in Exhibit C involve recipients located in foreign jurisdictions.
Public disclosure of their identities in connection with financial transfers may expose such individuals to legal, regulatory, or governmental scrutiny unrelated to this case.
In addition, some of the individuals identified in Exhibit C are related to jurisdictions with documented risks of governmental pressure or retaliation in connection with financial activity.
Publicly linking such individuals to cross-border transactions may increase their exposure to adverse consequences.
Public disclosure of such associations may itself create risk, particularly where engaging in financial activity with Plaintiff could be subject to adverse interpretation in certain foreign jurisdictions.
This risk is concrete and unnecessary given the limited relevance of the information.
D. Redaction Is a Narrowly Tailored Alternative
Defendant’s submission is not narrowly tailored. It discloses the entirety of Plaintiff’s transaction history, including information that is irrelevant to the issues before the Court.
Redaction of third-party identifying information would fully preserve any evidentiary value of Exhibit C while protecting sensitive information.
Thus, redaction, rather than wholesale public disclosure, is the least restrictive means of addressing the issue.
IV. REQUESTED RELIEF
Plaintiff respectfully requests that the Court:
- Order Defendant to file a redacted version of Exhibit C removing all third-party identifying information; or
- In the alternative, order that Exhibit C be filed under seal.
V. CONCLUSION
For the foregoing reasons, Plaintiff respectfully requests that the Court grant this Motion.
Dated at Baytown, Texas this 14th day of April 2026.
Respectfully submitted,
Youras Ziankovich, Esq.
Plaintiff Pro Se