Doe v. Alexander
- James Oetken
- 1:25-cv-02109
- U.S. District Court · Southern District of New York
- 1
In Doe v. Alexander, Judge Oetken required Jane Doe to seek permission to remain anonymous or use her real name, warning of dismissal.
Jane Doe must either request federal-court permission to proceed under a pseudonym or file an amended complaint using her real name by April 1, 2025; otherwise, the court will dismiss the complaint.
What happened
Jane Doe sued Tal Alexander in state court using a pseudonym, with permission from that court. After Alexander moved the case to federal court, the federal procedural rules applied.
The court said Jane Doe may still be allowed to proceed anonymously, but she must first ask the federal court for permission. The court required her either to file that request or to file an amended complaint using her real name by April 1, 2025.
The order did not decide the underlying dispute. Judge J. Paul Oetken warned that the court will dismiss the complaint if Jane Doe does not meet the deadline.
The detailed version
- Doe v. Alexander · No. 1:25-cv-02109
- James Oetken
- Mar. 18, 2025
Background
Jane Doe filed the complaint in state court under a pseudonym, with permission from that court. Tal Alexander removed the action to the U.S. District Court for the Southern District of New York.
Court’s Analysis
Judge J. Paul Oetken explained that, after removal, the case is governed by the Federal Rules of Civil Procedure. Those rules require the complaint’s title to name all parties. The court also explained that Jane Doe may still be able to proceed under a pseudonym, but she must first obtain permission from the federal court.
Order
The court required Jane Doe to do one of two things by April 1, 2025: file a motion asking for permission to proceed under a pseudonym, or file an amended complaint using her real name. The court stated that it will dismiss the complaint if she does neither. The order did not address the merits of the underlying dispute and did not state whether Jane Doe has counsel.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.