Doe v. Sequoia Capital Operations LLC
1:25-cv-06169
S.D.N.Y.Aug 20, 2025Background
- Plaintiff Amber Doe (pro se, Los Angeles) sues Sequoia-related defendants alleging a sex-trafficking operation.
- Doe previously filed substantially similar suits; SDNY transferred Doe I to the Central District of California (CDCA).
- CDCA had dismissed two earlier California actions by Doe and later denied IFP in the transferred Doe I as frivolous.
- This SDNY filing is duplicative of multiple cases already resolved or dismissed in CDCA; Doe also filed near-identical complaints in Middle District of Florida and D.C.
- Court considered Doe’s motion to recuse the judge and motions for electronic filing, TRO, and IFP; state courts and the California State Bar have labeled Doe a vexatious litigant.
- The court denied recusal and e-filing, reserved TRO and IFP rulings to the transferee court, transferred the case to CDCA under 28 U.S.C. § 1404(a), and certified any appeal would not be in good faith.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Recusal of the presiding judge | Judge should recuse for perceived bias based on prior transfer | Prior rulings do not show extrajudicial bias; dissatisfaction with rulings is insufficient | Denied — no objective basis for recusal under §455(a) and Liteky |
| Transfer to Central District of California | Case should proceed in SDNY | Action is duplicative; CDCA already considered similar claims and found them frivolous | Transferred to CDCA under §1404(a) in the interests of justice; CDCA best positioned to resolve |
| Interim procedural motions (IFP / TRO / e-filing) | Seeks IFP, TRO, and permission for electronic filing | Prior findings of frivolity and duplicative filings justify denial or deferral | E-filing denied; IFP/TRO rulings reserved for transferee; IFP for appeal denied (appeal not in good faith) |
Key Cases Cited
- Liteky v. United States, 510 U.S. 540 (1994) (judicial rulings alone almost never warrant recusal)
- United States v. Yousef, 327 F.3d 56 (2d Cir. 2003) (appearance-of-bias test from perspective of an objective observer)
- Lewis v. Tuscan Dairy Farms, Inc., 25 F.3d 1138 (2d Cir. 1994) (personal bias claims normally must rest on extrajudicial conduct)
- Fulton v. Robinson, 289 F.3d 188 (2d Cir. 2002) (speculation about a judge's acquaintance is insufficient for recusal)
- New York v. Exxon Corp., 932 F.2d 1020 (2d Cir. 1991) (strong presumption favoring the forum of the first-filed suit)
- Coppedge v. United States, 369 U.S. 438 (1962) (standard for determining good-faith in forma pauperis appeals)