Doe 1 v. Alexander
- Ronnie Abrams
- 1:25-cv-02108
- U.S. District Court · Southern District of New York
- 1
In Doe 1 v. Alexander, Judge Abrams gave Plaintiff until March 28 to seek permission to use a pseudonym or face dismissal.
Jane Doe 1 must seek federal court permission to continue using a pseudonym by March 28, 2025, or the Complaint will be dismissed. The order also affects Tal Alexander because it sets a procedural condition for continuing the case.
What happened
In Doe 1 v. Alexander, Jane Doe 1 filed the case in state court using a pseudonym, with permission from that court. Defendant Tal Alexander later moved the case to federal court.
Judge Abrams explained that federal procedural rules apply after removal and generally require a complaint’s title to name all parties. Plaintiff therefore may not continue using a pseudonym without first asking the federal court for permission.
The court ordered Plaintiff to file that request by March 28, 2025. Judge Ronnie Abrams stated that the court will dismiss the Complaint if Plaintiff does not meet that deadline; the court did not dismiss the Complaint in this order.
The detailed version
- Doe 1 v. Alexander · No. 1:25-cv-02108
- Ronnie Abrams
- Mar. 17, 2025
Background
Jane Doe 1 filed the Complaint in state court under a pseudonym, with that court’s permission. After Tal Alexander removed the action to the U.S. District Court for the Southern District of New York, federal procedural rules governed the case.
Issue
The court addressed whether Plaintiff could continue litigating under a pseudonym without first obtaining permission from the federal court. Federal Rule of Civil Procedure 10(a) generally requires a complaint’s title to name all parties. The court stated that Plaintiff could not proceed pseudonymously unless Plaintiff first sought and received permission to do so.
Order
The court directed Plaintiff to file a motion seeking permission to proceed under a pseudonym by March 28, 2025. The court stated that it will dismiss the Complaint if Plaintiff does not file that motion by the deadline. This order did not itself dismiss the Complaint and did not decide the underlying claims.
The order was signed by Ronnie Abrams, United States District Judge.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.