From Townsend v. The Gardens at Aldersgate LLC, decided Monday by Magistrate Judge Rachel Schwartz (D. Kan.):
This is a skilled-nursing-home negligence case proceeding in federal court based on diversity jurisdiction …. In diversity cases proceeding under § 1332(a), Federal Rule of Civil Procedure 7.1(a)(2) requires every "party or intervenor [to]…file a disclosure statement[ ] [that] must name—and identify the citizenship of—every individual or entity whose citizenship is attributed to that party or intervenor[.]" On August 3, 2026, Defendants filed their unredacted Rule 7.1 disclosure statements provisionally under seal. In the present Motion, Defendants seek to maintain under seal the unredacted Rule 7.1 disclosure statements, which reveal various layers of the respective limited liability companies' ("LLC") memberships and the identities of those layers of members. Defendants request permission to file publicly only redacted versions of these documents, redacting "the names of non-party individuals, trusts, and limited liability companies whose disclosure would reveal the private ownership and financial associations of non-parties." Plaintiffs oppose the Motion on multiple grounds, including that granting the Motion "would convert a transparency rule into a sealing regime for any LLC that prefers anonymity."
The court noted the general right of access to court records, and concludes that there's no exception to it for the LLC disclosures; here's part of the analysis:
