How have courts treated a plaintiff's request to seal post-judgment documents?

"Compensable work on post-judgment proceedings must be 'useful' and of a type 'ordinarily necessary' to secure the litigation's final result." [67 Cal.App.4th 456] (Stewart v. Gates (9th Cir.1993) 987 F.2d 1450, 1452.) While it is clear from the record that plaintiff desired full disclosure of all documents, his desire was not "ordinarily necessary" for him to secure the result obtained in this litigation. The underlying conduct for which plaintiff sought recompense was the wrongful disclosure of information about him by defendants. Although plaintiff prevailed on the motion and the trial court denied defendants' post-judgment request that the court files be sealed, it did so because the documents had already been in public files for some time and therefore could not be considered confidential. It did not find that disclosure of these documents was proper or appropriate. In fact, some of those documents were similar to those which plaintiff's action claimed had been wrongly disclosed. These documents simply contained information about individuals other than plaintiff.

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