Doe v. Combs, 1:24-cv-07776

Plaintiff alleged that Sean Combs drugged and sexually assaulted him at a 2007 party where plaintiff was providing security services, and that Combs' companies enabled the assault.
Plaintiff filed suit under New York City’s Victims of Gender-Motivated Violence Protection Act, naming multiple Combs-related companies as defendants.
Plaintiff sought permission to proceed under the pseudonym "John Doe" due to the sensitive nature of the allegations and claimed potential for psychological and physical harm if identified.
Defendants opposed the motion, arguing disclosure was necessary for fairness, discovery, and public interest.
Numerous similar anonymity motions in cases against Combs in the same district have been denied, with only one exception (decision to be revisited).
The court addressed factors from Sealed Plaintiff v. Sealed Defendant in evaluating the balance between anonymity, public interest, and potential prejudice to defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proceeding Anonymously	Sensitive, personal sexual assault allegations justify anonymity	Public interest and prejudice to defense outweigh anonymity; anonymity is exceptional	Denied: Plaintiffs in similar cases not anonymous; sensitive claims not dispositive
Risk of Harm from Disclosure	Disclosure would be traumatizing, risks mental/physical harm, especially amid media coverage	Plaintiff's risk claims are speculative, not particularized; no demonstrated retaliation risk	Denied: No specific or corroborated harm; statements speculative
Prejudice to Defendant	Defendants are not prejudiced; plaintiff unknown to Combs before/during/after assault	Anonymity creates asymmetry, hampers discovery, unfair to defend publicly against anonymous party	Denied: Concealment would prejudice discovery, fairness
Public Interest in Disclosure	Anonymity encourages other victims to come forward; public interest less in victim's identity	Public has strong interest in open judicial proceedings, especially against public figures	Denied: Public interest and fairness compelling; deterrence argument rejected

Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185 (2d Cir. 2008) (articulates factors for granting party anonymity)
U.S. v. Pilcher, 950 F.3d 39 (2d Cir. 2020) (pseudonyms are the exception, requiring concrete justification)
Rapp v. Fowler, 537 F. Supp. 3d 521 (S.D.N.Y. 2021) (denied anonymity in statutory rape case)
Doe v. Weinstein, 484 F. Supp. 3d 90 (S.D.N.Y. 2020) (explains factors against blanket anonymity in sexual assault cases)