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N.D. Cal.Procedural orderFiled Mar. 6, 2020

DOE v. Life Insurance Company of North America

Judge
James Donato
Docket
3:20-cv-00392
Court
U.S. District Court · Northern District of California
Pages
1
Civil Procedure
In one sentence

In John Doe v. Life Insurance, Judge Donato preliminarily allowed John Doe to serve his complaint under a pseudonym but required later review.

Who this affects

John Doe, whose request to proceed under a pseudonym was granted preliminarily, and the defendants, who may respond to a renewed request after being served.

What happened

John Doe asked in John Doe v. Life Insurance Company of North America to proceed under a fictitious name. No defendant had been served or appeared when the court considered the request.

The court granted the request on a preliminary basis. John Doe may serve his complaint using a pseudonym, but he must renew the request within 21 days after service if he wants to continue using one. The renewed request must be an administrative motion that gives defendants notice.

Judge James Donato said the court would reconsider the issue after defendants had an opportunity to respond and would not permanently grant broad anonymity at this stage.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
DOE v. Life Insurance Company of North America · No. 3:20-cv-00392
Judge
James Donato
Date
Mar. 6, 2020

Background

John Doe moved to proceed under a fictitious name. The order states that no defendant had been served or appeared when the court reviewed the request.

Court’s Analysis

The court noted that federal courts have a strong tradition of transparent litigation. It cited the public’s common-law right to access judicial proceedings and the rule generally requiring a complaint’s title to identify all parties. Because the case was at an early stage, the court was unwilling to permanently grant broad anonymity to John Doe without giving the defendants an opportunity to respond.

Ruling

The court granted John Doe’s request on a preliminary basis. He may serve his complaint under a pseudonym. If he wants to maintain that status, he may renew the request in an administrative motion with notice to the defendants within 21 days after service. The court stated that it would revisit the issue after defendants had an opportunity to respond.

The authoritative version

Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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