Grezak v. Grezak, 1:12-cv-04520

Pro se plaintiff Grazyna Sklodowska Grezak sued her daughter (Evelina Grezak) and a psychiatrist in 2012; most claims were later dismissed or narrowed and the case reflected a personal family dispute.
Plaintiff's relationship with her counsel (Darius Marzec) broke down; Marzec withdrew and was disqualified as her counsel in Dec. 2014.
Between Dec. 2014 and May 2015 plaintiff filed numerous motions, including sanctions and injunctions against defendant, defense counsel (Beth Finkelstein), and former counsel Marzec.
At a May 15, 2015 settlement conference before Magistrate Judge Pollak plaintiff agreed to dismiss the case and (after discussion) agreed that she would seek the magistrate judge’s prior approval before filing certain future pleadings.
Judge Pollak issued two post‑settlement orders: (1) Sanction Motions Order — denied plaintiff’s sanctions/injunction motions as moot and partly granted/denied restriction of certain docket entries; and (2) Leave‑to‑File Order — required plaintiff to obtain prior approval from Judge Pollak before filing new EDNY civil actions against defendant or filings in the case alleging breach of the settlement.
Plaintiff moved for reconsideration and appealed; plaintiff also sought to file a reply (docket entry 141) and accused defense counsel of misconduct. Defendant sought restriction of access to docket entry 141.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether magistrate judge's denial of sanctions/injunctions should be reconsidered	Grezak claims new evidence justifies sanctions/injunctions against Evelina, Finkelstein, Marzec	Orders moot because case settled; sanctions unwarranted	Denied — motions are moot after settlement and sanctions are not justified
Whether the leave‑to‑file requirement was procedurally improper	Grezak contends court failed to follow required notice/show‑cause procedure under 2d Cir. law	Magistrate warned plaintiff to stop duplicative filings; plaintiff agreed at conference; post‑settlement requirement is narrow	Denied — requirement was reasonable, plaintiff consented at conference; reconsideration treated as response to show‑cause
Whether voluntary settlement moots pending motions for sanctions/injunctions	Grezak argues settlement does not eliminate need for relief based on alleged misconduct	Settlement terminated the live controversy so requested relief is no longer necessary	Held moot — relief sought cannot be granted after stipulation of dismissal
Whether docket entry 141 should be restricted from public access	Grezak opposed restriction; asserted right to file reply publicly	Finkelstein argued the letter repeated baseless accusations and implicated reputational concerns	Granted — access restricted to case participants only due to low public‑access weight and reputational interests

Shrader v. CSX Transp., 70 F.3d 255 (2d Cir. 1995) (standard for reconsideration motions is strict)
Martin‑Trigona v. Shiff, 702 F.2d 380 (2d Cir. 1983) (settlement can render claims moot)
Moates v. Barkley, 147 F.3d 207 (2d Cir. 1998) (district courts may not impose filing injunctions sua sponte without notice and opportunity to be heard)
Iwachiw v. New York State Dep’t of Motor Vehicles, 396 F.3d 525 (2d Cir. 2005) (factors and procedure for filing‑restriction sanctions)
Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) (public right of access to judicial documents)
U.S. v. Amodeo, 71 F.3d 1040 (2d Cir. 1995) (weight of presumption of access depends on document’s role in adjudication)