Doe v. Alexander
- Ronnie Abrams
- 1:25-cv-02241
- U.S. District Court · Southern District of New York
- 2
In Doe v. Alexander, Judge Abrams denied Plaintiff’s request to seal a letter and required a redacted filing if needed.
The ruling affects the plaintiff’s request to seal the letter motion and Defendant John Doe’s request for confidentiality; it requires any claimed sensitive portions to be addressed through redactions rather than sealing the letter in its entirety.
What happened
In Doe v. Alexander, the plaintiff asked for permission to file a letter motion under seal. The letter discussed efforts to serve Hana Bolous and the delayed filing of proof of service for Defendant John Doe.
The plaintiff said sealing was requested because John Doe’s lawyer wanted his name kept private while seeking permission for him to proceed anonymously. That lawyer also believed John Doe had been mistakenly identified and was not the person described in the complaint. The defendants represented by counsel did not oppose sealing the letter.
Judge Ronnie Abrams denied the application. She found that the letter did not reveal Doe’s name or information that appeared capable of identifying him, and that the plaintiff gave no reason to seal the discussion of service efforts. Judge Abrams ordered that any sensitive portions instead be filed in a redacted version by July 14, 2025, with an explanation supporting each redaction.
The detailed version
- Doe v. Alexander · No. 1:25-cv-02241
- Ronnie Abrams
- July 7, 2025
Background
Plaintiff’s counsel asked for permission to file an accompanying letter motion under seal. The letter concerned counsel’s efforts to serve Hana Bolous and the delay in filing the certificate of service for Defendant John Doe, as required by the Court’s June 27, 2025 order.
Plaintiff said the request to seal was made at the request of counsel for John Doe. That counsel wanted Doe’s identity kept private until Doe could enter an appearance and seek permission to proceed anonymously. Counsel also believed that Doe had been mistakenly identified and was not the person described in the complaint. Counsel for the Alexander defendants did not oppose the request.
Ruling
The court denied the application. It explained that the letter did not reveal Doe’s name and did not appear to contain information that could identify him. The court also found that Plaintiff gave no reason to seal the discussion of efforts to serve Bolous. Accordingly, there was no basis to seal the letter in its entirety.
The court stated that, if Plaintiff believed particular portions were sensitive, Plaintiff had to file a redacted version of the letter by July 14, 2025, together with a letter explaining why the redactions were justified under the standard in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006).
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.