# A Sealing Chart Maps Evidence Before Anything Is Unsealed ## Claim A rule-required sealing chart discloses the source and structure of hidden evidence, so a reader can reconstruct a motion's evidentiary skeleton before any content is unsealed. <!-- atomicity: 1 idea ✓ --> ## Scope & conditions - Holds under local rules (like N.D. Cal. Civil L.R. 79-5) that require the filer to itemize which passages/exhibits derive from which confidential source, rather than permitting blanket sealing. - The information gained is structural (which declarations, depositions, or documents are load-bearing) — not substantive; the chart never reveals what the sealed material says. - Breaks down where courts allow undifferentiated or blanket sealing without per-item source attribution. ## Evidence In WPE v. Automattic Dkt. 358, WPE's sealing chart names every confidential source behind its spoliation sanctions motion without revealing content: a Jonathan Robins declaration, a Mullenweg declaration and his second deposition volume, a Jesse Friedman deposition, and four Automattic Bates-numbered document ranges. The repeated reliance on the Robins declaration and Mullenweg's second deposition volume across most chart rows is itself informative — it suggests those two sources are the evidentiary core of the spoliation theory, an inference drawable from the chart's structure alone, before either document's content is public. ## Links - [[3. Resources/Permanent Notes/A Legal Hold Without Prompt Device Imaging Is Not Preservation]] — because applies-in: the same Robins-declaration/Mullenweg-deposition evidentiary core surfaces in both notes. - [[3. Resources/Literature Notes/WPE v Automattic Dkt 368 — Defendants' Statement on Sealing - Literature Note]] — because extends: Defendants' response to this same chart shows which items they contest versus concede. - [[3. Resources/MOCs/Open Source Governance MOC]] — because applies-in: tracking litigation transparency as a governance-accountability mechanism. ## Tests / falsifiers - Once Defendants' Rule 79-5(f)(3) statement and any later unsealing land, check whether the sources the chart weighted most heavily (Robins declaration, Mullenweg deposition vol. 2) turn out to be the actual evidentiary core — a chart that over- or under-weights the real center would falsify the "chart as evidence map" reading. ## Maintenance - Last tended: 2026-08-16 - Next review: 2026-11-16 ## Source - [[3. Resources/Literature Notes/WPE v Automattic Dkt 358 — Admin Motion to Seal - Literature Note]] — WPE's two sealing charts (redacted passages and fully sealed exhibits) and their confidential-source attributions.