Doe v. James P. Ehrhard Esq.
- Rearden
- 1:25-cv-05724
- U.S. District Court · Southern District of New York
- 2
In Doe v. Ehrhard, Judge Rearden ordered the pseudonymous plaintiff to seek permission to remain anonymous and disclose his identity under seal.
John Doe, whose request to proceed under a pseudonym had not yet been authorized, and the defendants and court, in connection with the required disclosure and anonymity procedures.
What happened
In John Doe v. James P. Ehrhard Esq. et al., the complaint was filed using a pseudonym without first obtaining the court’s permission. The court cited the rule generally requiring parties to be named in a complaint’s title and the presumption that court proceedings are open.
The court directed John Doe to file, by August 1, 2025, a motion asking for permission to proceed under a pseudonym. It also directed him to file, by July 29, 2025, a sealed declaration disclosing his identity so the court could check for conflicts requiring the judge’s recusal.
Judge Jennifer H. Rearden ordered that failure to seek permission would result in the plaintiff being named without further notice. The order addressed anonymity and court administration; it did not decide the underlying claims.
The detailed version
- Doe v. James P. Ehrhard Esq. · No. 1:25-cv-05724
- Rearden
- July 24, 2025
Background
John Doe filed the complaint under a pseudonym without obtaining permission from the court. The opinion states that the underlying complaint was originally filed in New York State Supreme Court, Bronx County, on June 12, 2025, and was later filed in this case.
Court’s Analysis
Federal Rule of Civil Procedure 10(a) generally requires that all parties be identified in the title of a complaint. The court explained that a plaintiff may proceed anonymously only after asking for and receiving permission. It also noted that a court may allow anonymity when the plaintiff’s privacy interest substantially outweighs prejudice to the opposing party and the usual presumption that judicial proceedings are open.
Order
The court ordered John Doe to file a motion for permission to proceed under a pseudonym by August 1, 2025. If he failed to comply, he would be named without further notice.
The court separately ordered John Doe to file a declaration disclosing his identity under seal by July 29, 2025. The declaration was required so the court could check for conflicts that might require recusal. The court instructed him to title it “Declaration of John Doe” so his name would not appear on the public docket.
The order did not resolve the merits of the claims against the defendants.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.