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Jane Doe v. John Doe and John Doe Corp.
1:16-cv-02050
S.D.N.Y.
Aug 9, 2017
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Background

  • Plaintiff filed a civil action in S.D.N.Y.; the case proceeded publicly for over a year and included defendants' counterclaims.
  • The parties jointly moved to retroactively assign pseudonyms to all parties on the docket and in all publicly available filings after settlement.
  • Parties asserted economic harm and embarrassment from the public allegations as reasons for anonymity.
  • Neither party alleged vulnerability or risk of physical retaliation; there was no finding of fault because the case settled.
  • The Court considered the public’s interest in open proceedings and the precedent requiring balancing of anonymity against disclosure.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether parties may proceed under pseudonyms retroactively for all filings Joint request: economic/reputational harm and embarrassment justify sealing identities Agreed to joint request; no contention of physical harm or vulnerability Denied for full retroactive anonymity; allowed limited caption masking because parties jointly requested and case settled without fault
Whether embarrassment/economic harm alone supports anonymity Embarrassment and alleged economic harm warrant sealing Opposing party had litigated publicly without pseudonyms; public interest weighs against sealing Court: embarrassment/reputational harm insufficient to justify retroactive sealing
Whether the public’s right to access outweighs privacy here Privacy interests reduced after settlement; seek to minimize publicity Public interest in disclosure; lawsuits are public events Court balanced interests and ordered limited sealing of caption only
Scope of relief (caption-only vs. all documents) Requested full retroactive pseudonymity for all docketed filings Not disputed by parties but court considered precedent and burden Court ordered caption to show Jane Doe and John Doe Corp./John Doe; denied retroactive redaction of prior filings

Key Cases Cited

  • Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185 (2d Cir. 2008) (sets balancing test for pseudonymous litigation and emphasizes public’s right to know who uses the courts)
  • M.M. v. Zavaras, 139 F.3d 798 (10th Cir. 1998) (embarrassment or reputational harm alone does not justify anonymity)
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Case Details

Case Name: Jane Doe v. John Doe and John Doe Corp.
Court Name: District Court, S.D. New York
Date Published: Aug 9, 2017
Docket Number: 1:16-cv-02050
Court Abbreviation: S.D.N.Y.