Watson v. NY Doe 1
- Figueredo
- 1:19-cv-00533
- U.S. District Court · Southern District of New York
- 2
In Watson v. NY Doe 1, Judge Figueredo ordered protection for an anonymous witness’s identity and contact information in the litigation.
Anonymous non-party witness 1, whose identity and contact information were protected from public and other unauthorized disclosure; people necessary to the litigation may receive the information if they agree to follow the protective order.
What happened
Watson v. NY Doe 1 involved an anonymous non-party witness who asked the court to protect the witness’s identity and contact information from disclosure, including to the public. The witness had been required to provide sworn testimony after NY Doe 2 issued a subpoena.
No party opposed the request. The court explained that Federal Rule of Civil Procedure 26(c) allows protection from annoyance, embarrassment, oppression, or undue burden when good cause exists. The court found good cause based on reasons stated in the witness’s motion and noted that similar protections already covered some parties in the case.
Judge Valerie Figueredo ordered the requested protection and directed the Clerk of Court to terminate the motions filed at ECF Nos. 184, 186, and 187. The protection covers the witness’s identity and contact information, with disclosure limited to people necessary for the litigation who agree to follow the protective order.
The detailed version
- Watson v. NY Doe 1 · No. 1:19-cv-00533
- Figueredo
- Mar. 6, 2024
Background
An anonymous non-party witness, identified in the opinion as “Witness,” sought a protective order at ECF Nos. 184, 186, and 187. The requested order would protect the witness’s identity and contact information from disclosure to anyone, including the public, except people necessary to the litigation who agreed to be bound by the order.
The opinion states that the witness was compelled to provide sworn testimony through a Federal Rule of Civil Procedure 45 subpoena issued by NY Doe 2. The requested protection was similar to two protective orders already in place in the case. One existing order protected the identity and contact information of all defendants except NY Doe 3.
Court’s Analysis
Under Rule 26(c), a court may issue a protective order to protect a party or other person from annoyance, embarrassment, oppression, or undue burden and expense. The court explained that such an order requires good cause. No party opposed the witness’s request.
The court found that good cause existed for issuing the protective order based on the reasons stated by the witness in the motion, particularly ECF No. 187 at pages 6–7. The opinion does not describe those reasons in detail.
Disposition
The court issued the requested protection for the witness and directed the Clerk of Court to terminate the motions at ECF Nos. 184, 186, and 187. The opinion does not reproduce the full text of the protective order.
Judge Valerie Figueredo signed the order on March 6, 2024.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.