DOE v. FEDERAL REPUBLIC OF GERMANY, 680 F.Supp.3d 1

Plaintiff (pro se, using the pseudonym John Doe) alleges he was the source of the Panama Papers and sues the Federal Republic of Germany and its federal criminal police for breach of contract to recover money paid for those documents.
Doe initially sought to proceed under a pseudonym; an earlier two-page motion was denied without prejudice for failing to apply the governing legal standard. He filed a renewed Motion to Proceed Under a Pseudonym claiming "real and imminent" threats to his safety from foreign governments, criminal organizations, and wealthy exposed individuals.
The Court applied the D.C. Circuit’s five-factor, fact-driven balancing test for pseudonymous filings (In re Sealed Case) and focused especially on the risk of retaliatory harm. The Court found Doe’s allegations and public record of retaliation against Panama Papers participants sufficiently specific at this stage.
The Court granted permission to proceed pseudonymously in public filings (ordering redaction of Doe’s name and address) but denied Doe’s request to withhold his identity from the Court.
The Court concluded Local Rule 5.1(c)(1) and the Federal Rules require the court to have the plaintiff’s true name, residential address, and telephone number; it ordered Doe to file those details ex parte and under seal within 21 days.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Doe may proceed publicly under a pseudonym	Safety threats from foreign states, criminal groups, and exposed individuals justify anonymity	Public interest favors openness; suits may require transparency	Granted: factors 1 (sensitive privacy), 2 (risk of retaliation), and 5 (no unfairness) favor pseudonymity; factors 3 and 4 neutral
Whether Doe may withhold his identity from the Court (no sealed name/address/phone)	Court systems vulnerable to breach; will only provide email and secret passphrase, not name/phone/address	Local and Federal Rules require party name and contact information to be disclosed to court (and can be filed under seal)	Denied: Doe must file true name, residential address, and phone ex parte and under seal; no precedent for total withholding
Whether providing a telephone number uniquely increases risk	Phone can be used to track him immediately; thus should be exempted	No specific risk shown beyond that posed by residential address; no court granted phone exemption	Denied: Court not persuaded phone poses distinct risk and requires phone number under seal until counsel appears
Whether pseudonymity would unfairly prejudice Defendants	Doe asserts Defendants already know his identity so no unfairness	Defendants may argue transparency and ability to defend	Held: No unfairness shown; if Defendants lack necessary information they may seek it; knowing identity makes factor inapplicable

In re Sealed Case, 931 F.3d 92 (D.C. Cir. 2019) (articulating public-disclosure presumption and principles for pseudonymous filings)
In re Sealed Case, 971 F.3d 324 (D.C. Cir. 2020) (establishing five-factor, flexible balancing test for pseudonymity)
Washington Legal Found. v. U.S. Sentencing Comm’n, 89 F.3d 897 (D.C. Cir. 1996) (public interest in open judicial proceedings)
Doe v. Bogan, 542 F. Supp. 3d 19 (D.D.C. 2021) (discussing privacy-sensitive matters in pseudonymity analysis)
Chang v. Republic of South Sudan, 548 F. Supp. 3d 34 (D.D.C. 2021) (considering retaliation risk from foreign governments)
Qualls v. Rumsfeld, 228 F.R.D. 8 (D.D.C. 2005) (treatment of requests to waive naming requirements for pseudonymous complaints)
Doe v. Cabrera, 307 F.R.D. 1 (D.D.C. 2014) (distinguishing government defendants’ reputational interests from private litigants)
Doe 1 v. George Washington Univ., 369 F. Supp. 3d 49 (D.D.C. 2019) (distinguishing private litigants’ reputational concerns in pseudonymity contexts)
J.W. v. District of Columbia, 318 F.R.D. 196 (D.D.C. 2016) (addressing transparency considerations when government is a defendant)