Many courts are quite willing to allow plaintiffs to proceed as Jane or John Does in sexual assault cases, see pp. 1430-34 of The Law of Pseudonymous Litigation . But for reasons that I can't explain (and that might just be path-dependent, based on the outcomes of a few early precedents), the U.S. District Court for the Southern District of New York appears to be much more skeptical of that. The many cases against Sean Combs have turned in that direction, with a few early decisions tentatively allowing pseudonymity being later reconsidered; see this May 13 decision by Judge Valerie Caproni, which is the ninth S.D.N.Y. lawsuit against Combs saying no to pseudonymity.

The same has been true of many still other cases. Here, for instance, is Judge Colleen McMahon's decision May 14 in A.P. v.

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