Anonymous / Pseudonymous Plaintiff

In Doe v. Louis Leonelli et al, brought under the New York City Victims of Gender-Motivated Violence Act, NYC Administrative Code § 10-1105, the court denied plaintiff’s (unopposed) motion to proceed pseudonymously. The court stated the applicable black-letter law as follows: Rule 10(a) of the Federal Rules of Civil Procedure provides that the “title of…

Read More Plaintiff May Not Proceed Pseudonymously in Priest Sex Abuse Case
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In Twersky v. Yeshiva University et al, 2022 NY Slip Op 00366 (NY App. Div. 1st Dept. Jan. 20, 2022), the New York Appellate Division, First Department reversed a lower court decision permitting 33 Child Victims Act (CVA) plaintiffs to proceed under pseudonyms. The court summarized the law as follows: Several New York courts “have…

Read More Child Victims Act (CVA) Plaintiffs May Not Proceed Anonymously, Court Holds
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In Doe v. Bloomberg L.P., 2021 NY Slip Op 06754 (N.Y. App. Div. 1st Dept. Dec. 2 2021), the Appellate Division, First Department, held that the plaintiff may pursue her claims against Bloomberg L.P. – including for employment discrimination and sexual harassment – pseudonymously. From the decision: The presumption in favor of open trials and…

Read More Sexual Harassment Plaintiff May Continue to Proceed Under a Pseudonym in Case Against Bloomberg L.P.
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In John Doe v. The City of New York et al, 511209/2020, 2021 N.Y. Slip Op. 50916(U), 2021 WL 4468869 (Sup Ct, Sept. 29, 2021), the court (after largely dismissing plaintiff’s hostile work environment claims) denied plaintiff’s cross-motion to proceed under a pseudonym. While relatively short, the court’s analysis is instructive. It explained: Lastly, the…

Read More Sexual Harassment Plaintiff May Not Proceed Pseudonymously, Court Holds
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In a recently-filed lawsuit, captioned J.C. v. Robert Allen Zimmerman a/k/a Bob Dylan (Sup. Ct. N.Y. Cty. Index No. 951450/2021), the plaintiff – proceeding pseudonymously – asserts (under the Child Victims Act and pursuant to CPLR 214-g and 22 NYCRR § 202.72) that the defendant sexually abused her over a six-week period between April and…

Read More Child Victims Act Sex Abuse Lawsuit Against Bob Dylan
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In a recent Order in Doe v. Cuba Gooding, Jr. (SDNY, 20-cv–6569) – in which the plaintiff alleges that defendant, Cuba Gooding, Jr., forcibly raped her in 2013 – the Court (i) granted the plaintiff’s motions to proceed pseudonymously, (ii) granted the plaintiff’s motion for default judgment as to defendant’s liability, and (iii) reserved judgment as…

Read More Default Judgment Issued in Cuba Gooding, Jr. Rape Case
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In Doe v. Bloomberg, LP, No. 451470/2020, 2020 WL 7495654, 2020 N.Y. Slip Op. 34235(U) (N.Y. Sup Ct, New York County Dec. 21, 2020), a sexual harassment case, the court granted defendants’ motion to compel plaintiff to amend the caption of the action to reflect her name. The court summarized the guiding principles relating to this…

Read More Sexual Harassment Plaintiff May Not Proceed Anonymously, Court Rules
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In Jane Doe v. John Doe,[1]Ed. note: I have modified the name of Defendant to “John Doe” in light of (yet without acknowledging any obligation imposed by) the Court’s Order dated Nov. 5, 2021, NYSCEF Doc. No. 60. 155961/2020, 2020 NY Slip Op 33766(U) (N.Y. Sup. Ct. Nov. 12, 2020), the court granted plaintiff’s motion…

Read More Nanny Permitted to Proceed With Sexual Harassment/Assault Case Under Pseudonym
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In Doe v. Macfarland, 2019 NY Slip Op 29380 (NY Sup. Ct. Rockland County Dec. 10, 2019), the court addressed an issue that comes up in the context of, among other types of cases, those involving claims under New York’s newly-enacted Child Victims Act – namely, whether the plaintiff may proceed anonymously. The Child Victims…

Read More Court Permits “Child Victims Act” Plaintiff to Proceed Under Pseudonym
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In Doe v. Gong Xi Fa Cai, Inc. d/b/a Alta Restaurant, 2019 WL 3034793 (SDNY July 10, 2019) – in which plaintiff asserts claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e et seq. and other statutes for alleged sexual discrimination and retaliation – the court denied plaintiff’s motion to…

Read More Sexual Harassment Plaintiff May Not Proceed Anonymously, Court Concludes Upon Application of 10-Factor Test
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