1 Nevada Bar No. 10096 BRADLEY J. MYERS, ESQ. 2 Nevada Bar No. 8857 JOEL S. HENGSTLER, ESQ. 3 Nevada Bar No. 11597 THE702FIRM INJURY ATTORNEYS 4 8335 West Flamingo Road Las Vegas, Nevada 89147 5 Telephone: (702) 776-3333 Facsimile: (702) 505-9787 6 E-Mail: service@the702firm.com 7 GEOFFREY C. PARKER, ESQ. Nevada Bar No. 16952 8 JONATHAN L. HILTON, ESQ. Nevada Bar No. 16889 9 HILTON PARKER LLC 7658 Slate Ridge Boulevard 10 Reynoldsburg, Ohio 43068 Telephone: (614) 992-2277 11 Facsimile: (614) 927-5980 E-Mail: gparker@hiltonparker.com 12 13 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 14 ALICE J., pseudonymously, Case No.: 3:25-cv-00246 -MMD-CSD 15 Plaintiff, Judge Miranda M. Du 16 vs. Mag. Judge Craig S. Denney 17 J RESORTS, LLC f/k/a JESR, LLC, ORDER GRANTING PLAINTIFF’S UNOPPOSED 18 Defendant. MOTION FOR LEAVE TO PROCEED 19 UNDER A PSEUDONYM 20 COMES NOW Plaintiff Alice J., by and through her counsel of record, and respectfully 21 moves this Court to allow Plaintiff to proceed under the pseudonym “Alice J.” for pretrial 22 proceedings due to the sensitive nature of the a llegations in this case and her status as a sex 23 trafficking survivor. In support of the instant Motion, Plaintiff states as follows: 24 I. INTRODUCTION 25 This case involves claims brought by Plaintiff Alice J., a victim of sex trafficking, against 26 Defendants J Resorts, LLC, f/k/a JESR, LLC, who owned and operated the Sands Regency Casino 27 Hotel where Plaintiff was trafficked. Plaintiff alleges that she has suffered physical and sexual 28 1 violence, commercial sexual exploitation, and trauma from being trafficked on Defendant’s 2 property. 3 Given the highly sensitive and deeply personal nature of these allegations, Plaintiff seeks 4 leave to proceed under the pseudonym “Alice J.” to avoid further trauma and stigma associated 5 with being publicly named as a victim of sex trafficking and the possibility of retaliation by her 6 trafficker. For these reasons, leave to proceed under a pseudonym is widely granted for sex 7 trafficking victims. 8 Allowing Plaintiff to proceed under a pseudonym will not prejudice Defendant. Plaintiff is 9 ready to disclose her true identity to Defendant upon entry of Protective Order governing the use 10 and protection of that information in this litigation. Furthermore, the public’s interest in Plaintiff’s 11 identity is minimal, as disclosure would not meaningfully advance the public’s understanding of 12 the legal issues in this case. Good cause exists in allowing Plaintiff to proceed under a pseudonym. 13 Plaintiff’s counsel has met and conferred with counsel for the Defendant J Resorts, LLC 14 f/k/a JESR, LLC. Defendant does not oppose the relief sought herein. There is no accompanying 15 proposed order because it will be more efficient to incorporate specific protections for Plaintiff’s 16 identity in a stipulated protective order covering the treatment of all confidential information after 17 the stay in discovery has been lifted. 18 II. BACKGROUND 19 Plaintiff filed her First Amended Complaint under the pseudonym “Alice J.” on April 6, 20 2026, alleging violations of the Trafficking Victims Protection Reauthorization Act (“TVPRA”), 21 18 U.S.C. § 1595. (First Amended Complaint, Doc. 62.) She now seeks leave to continue using 22 this pseudonym in all public pretrial proceedings. 23 Plaintiff Alice J. is a victim of sex trafficking within the meaning of the TVPRA. See, e.g., 24 (Doc. 62.) Alice was trafficked for several years by an abusive pimp who routinely abused her, 25 confiscated all her earnings, and used drugs to coerce her into commercial sex acts. (Id. at ¶¶ 72, 26 78, 95–101.) On several occasions, Plaintiff was traffi cked at the Sands Regency Casino Hotel, 27 owned and operated by Defendant, including four commercial sex transactions with a Sands 28 employee who knew Alice was being abused and coerced by her trafficker. (Id. at ¶¶ 95, 104–107, 1 117–128.) 2 At this time, Alice has not received justice for her trafficking and all those responsible have 3 not been held accountable. She still suffers from the trauma of being trafficked for several years 4 in Reno, including at the Sands Regency Casino Hotel. (Id. at ¶103.) Leave to proceed under 5 pseudonym will allow her to pursue her legal rights without being publicly associated with such a 6 traumatic period of her life and without fear of retaliation from her trafficker or his associates. 7 III. STANDARD OF REVIEW 8 A complaint must state the names of all parties. Fed. R. Civ. P. 10(a). However, parties 9 may use pseudonyms in special circumstances where nondisclosure of their identity is necessary 10 to protect them “from harassment, injury, ridicule or personal embarrassment.” Does I thru XXIII 11 v.Advanced Textile Corp., 214 F.3d 1058, 1067–68 (9th Cir. 2000) (citation omitted). 12 District courts have broad discretion in determining whether a party may proceed 13 anonymously. Id. at 1068–69; Doe v. Kamehameha Schs./Bernice Pauahi Bishop Estate, 596 F.3d 14 1036, 1045–46 (9th Cir. 2010). In exercising that discretion, courts balance the need for anonymity 15 against both the prejudice to the opposing party and the public interest in knowing the party’s 16 identity. Advanced Textile, 214 F.3d at 1068. 17 The Ninth Circuit has identified three general circumstances when it may be appropriate 18 for a party to proceed under a pseudonym: (1) when identification creates a risk of retaliatory 19 physical or mental harm; (2) when anonymity is necessary to preserve privacy in a matter of a 20 sensitive and highly personal nature; and (3) when the anonymous party is compelled to admit his 21 or her intention to engage in illegal conduct, thereby risking criminal prosecution. Id. at 1068. 22 In deciding whether to grant leave to proceed under a pseudonym, courts considers: “(1) 23 the severity of the threatened harm; (2) the reasonableness of the anonymous party’s fears; (3) the 24 anonymous party’s vulnerability to such retaliation; (4) the prejudice to the opposing party; and 25 (5) the public interest.” Kamehameha Schs., 596 F.3d 1036, 1042. 26 IV. LAW AND ARGUMENT 27 Plaintiff has alleged that she is a victim of sex trafficking induced by force, fraud, and 28 coercion by her trafficker to have sex with johns and a casino manager at Defendant’s subject 1 casino hotel. As a result of Defendant’s alleged actions, Plaintiff was trafficked and sold for 2 commercial sex to several johns and an employee at the Sands Regency Casino Hotel on multiple 3 occasions. Plaintiff still suffers as a result of the trauma and sexual violence she endured. 4 Courts regularly allow sex trafficking and sexual assault survivors to proceed anonymously 5 because such cases involve “highly sensitive and personal” allegations. See, e.g., P.C. v. D Fort 6 Hotel, LLC., Civil No. 24-cv-1584-PAB-TPO, 2025 U.S. Dist. LEXIS 20835, *10 (D. Colo. Feb. 7 5, 2025) (finding that Plaintiff’s status as a victim of trafficking and sexual assault constitutes an 8 exceptional case of a highly sensitive and personal nature); Doe No. 2 v. Kolko, 242 F.R.D. 193, 9 195 (E.D.N.Y. 2006); Doe v. Cabrera, 307 F.R.D. 1, 5 (D.D.C. 2014). 10 Having been coerced into selling one’s body is something most survivors reasonably want 11 to keep private. Cases involving sex trafficking “inherently involve intimate matters,” and public 12 disclosure subjects victims to the “very real stigma associated with sex trafficking” and the “threat 13 of retaliation” by traffickers or their associates. Doe v. Wyndham Hotels & Resorts, No. 1:24-CV 14 285-RP, 2025 U.S. Dist. LEXIS 34711, at *6 (W.D. Tex. Feb. 25, 2025). Moreover, courts have 15 held that social stigma alone may justify proceeding anonymously. Doe v. Neverson, 820 F.
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1 Nevada Bar No. 10096 BRADLEY J. MYERS, ESQ. 2 Nevada Bar No. 8857 JOEL S. HENGSTLER, ESQ. 3 Nevada Bar No. 11597 THE702FIRM INJURY ATTORNEYS 4 8335 West Flamingo Road Las Vegas, Nevada 89147 5 Telephone: (702) 776-3333 Facsimile: (702) 505-9787 6 E-Mail: service@the702firm.com 7 GEOFFREY C. PARKER, ESQ. Nevada Bar No. 16952 8 JONATHAN L. HILTON, ESQ. Nevada Bar No. 16889 9 HILTON PARKER LLC 7658 Slate Ridge Boulevard 10 Reynoldsburg, Ohio 43068 Telephone: (614) 992-2277 11 Facsimile: (614) 927-5980 E-Mail: gparker@hiltonparker.com 12 13 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 14 ALICE J., pseudonymously, Case No.: 3:25-cv-00246 -MMD-CSD 15 Plaintiff, Judge Miranda M. Du 16 vs. Mag. Judge Craig S. Denney 17 J RESORTS, LLC f/k/a JESR, LLC, ORDER GRANTING PLAINTIFF’S UNOPPOSED 18 Defendant. MOTION FOR LEAVE TO PROCEED 19 UNDER A PSEUDONYM 20 COMES NOW Plaintiff Alice J., by and through her counsel of record, and respectfully 21 moves this Court to allow Plaintiff to proceed under the pseudonym “Alice J.” for pretrial 22 proceedings due to the sensitive nature of the a llegations in this case and her status as a sex 23 trafficking survivor. In support of the instant Motion, Plaintiff states as follows: 24 I. INTRODUCTION 25 This case involves claims brought by Plaintiff Alice J., a victim of sex trafficking, against 26 Defendants J Resorts, LLC, f/k/a JESR, LLC, who owned and operated the Sands Regency Casino 27 Hotel where Plaintiff was trafficked. Plaintiff alleges that she has suffered physical and sexual 28 1 violence, commercial sexual exploitation, and trauma from being trafficked on Defendant’s 2 property. 3 Given the highly sensitive and deeply personal nature of these allegations, Plaintiff seeks 4 leave to proceed under the pseudonym “Alice J.” to avoid further trauma and stigma associated 5 with being publicly named as a victim of sex trafficking and the possibility of retaliation by her 6 trafficker. For these reasons, leave to proceed under a pseudonym is widely granted for sex 7 trafficking victims. 8 Allowing Plaintiff to proceed under a pseudonym will not prejudice Defendant. Plaintiff is 9 ready to disclose her true identity to Defendant upon entry of Protective Order governing the use 10 and protection of that information in this litigation. Furthermore, the public’s interest in Plaintiff’s 11 identity is minimal, as disclosure would not meaningfully advance the public’s understanding of 12 the legal issues in this case. Good cause exists in allowing Plaintiff to proceed under a pseudonym. 13 Plaintiff’s counsel has met and conferred with counsel for the Defendant J Resorts, LLC 14 f/k/a JESR, LLC. Defendant does not oppose the relief sought herein. There is no accompanying 15 proposed order because it will be more efficient to incorporate specific protections for Plaintiff’s 16 identity in a stipulated protective order covering the treatment of all confidential information after 17 the stay in discovery has been lifted. 18 II. BACKGROUND 19 Plaintiff filed her First Amended Complaint under the pseudonym “Alice J.” on April 6, 20 2026, alleging violations of the Trafficking Victims Protection Reauthorization Act (“TVPRA”), 21 18 U.S.C. § 1595. (First Amended Complaint, Doc. 62.) She now seeks leave to continue using 22 this pseudonym in all public pretrial proceedings. 23 Plaintiff Alice J. is a victim of sex trafficking within the meaning of the TVPRA. See, e.g., 24 (Doc. 62.) Alice was trafficked for several years by an abusive pimp who routinely abused her, 25 confiscated all her earnings, and used drugs to coerce her into commercial sex acts. (Id. at ¶¶ 72, 26 78, 95–101.) On several occasions, Plaintiff was traffi cked at the Sands Regency Casino Hotel, 27 owned and operated by Defendant, including four commercial sex transactions with a Sands 28 employee who knew Alice was being abused and coerced by her trafficker. (Id. at ¶¶ 95, 104–107, 1 117–128.) 2 At this time, Alice has not received justice for her trafficking and all those responsible have 3 not been held accountable. She still suffers from the trauma of being trafficked for several years 4 in Reno, including at the Sands Regency Casino Hotel. (Id. at ¶103.) Leave to proceed under 5 pseudonym will allow her to pursue her legal rights without being publicly associated with such a 6 traumatic period of her life and without fear of retaliation from her trafficker or his associates. 7 III. STANDARD OF REVIEW 8 A complaint must state the names of all parties. Fed. R. Civ. P. 10(a). However, parties 9 may use pseudonyms in special circumstances where nondisclosure of their identity is necessary 10 to protect them “from harassment, injury, ridicule or personal embarrassment.” Does I thru XXIII 11 v.Advanced Textile Corp., 214 F.3d 1058, 1067–68 (9th Cir. 2000) (citation omitted). 12 District courts have broad discretion in determining whether a party may proceed 13 anonymously. Id. at 1068–69; Doe v. Kamehameha Schs./Bernice Pauahi Bishop Estate, 596 F.3d 14 1036, 1045–46 (9th Cir. 2010). In exercising that discretion, courts balance the need for anonymity 15 against both the prejudice to the opposing party and the public interest in knowing the party’s 16 identity. Advanced Textile, 214 F.3d at 1068. 17 The Ninth Circuit has identified three general circumstances when it may be appropriate 18 for a party to proceed under a pseudonym: (1) when identification creates a risk of retaliatory 19 physical or mental harm; (2) when anonymity is necessary to preserve privacy in a matter of a 20 sensitive and highly personal nature; and (3) when the anonymous party is compelled to admit his 21 or her intention to engage in illegal conduct, thereby risking criminal prosecution. Id. at 1068. 22 In deciding whether to grant leave to proceed under a pseudonym, courts considers: “(1) 23 the severity of the threatened harm; (2) the reasonableness of the anonymous party’s fears; (3) the 24 anonymous party’s vulnerability to such retaliation; (4) the prejudice to the opposing party; and 25 (5) the public interest.” Kamehameha Schs., 596 F.3d 1036, 1042. 26 IV. LAW AND ARGUMENT 27 Plaintiff has alleged that she is a victim of sex trafficking induced by force, fraud, and 28 coercion by her trafficker to have sex with johns and a casino manager at Defendant’s subject 1 casino hotel. As a result of Defendant’s alleged actions, Plaintiff was trafficked and sold for 2 commercial sex to several johns and an employee at the Sands Regency Casino Hotel on multiple 3 occasions. Plaintiff still suffers as a result of the trauma and sexual violence she endured. 4 Courts regularly allow sex trafficking and sexual assault survivors to proceed anonymously 5 because such cases involve “highly sensitive and personal” allegations. See, e.g., P.C. v. D Fort 6 Hotel, LLC., Civil No. 24-cv-1584-PAB-TPO, 2025 U.S. Dist. LEXIS 20835, *10 (D. Colo. Feb. 7 5, 2025) (finding that Plaintiff’s status as a victim of trafficking and sexual assault constitutes an 8 exceptional case of a highly sensitive and personal nature); Doe No. 2 v. Kolko, 242 F.R.D. 193, 9 195 (E.D.N.Y. 2006); Doe v. Cabrera, 307 F.R.D. 1, 5 (D.D.C. 2014). 10 Having been coerced into selling one’s body is something most survivors reasonably want 11 to keep private. Cases involving sex trafficking “inherently involve intimate matters,” and public 12 disclosure subjects victims to the “very real stigma associated with sex trafficking” and the “threat 13 of retaliation” by traffickers or their associates. Doe v. Wyndham Hotels & Resorts, No. 1:24-CV 14 285-RP, 2025 U.S. Dist. LEXIS 34711, at *6 (W.D. Tex. Feb. 25, 2025). Moreover, courts have 15 held that social stigma alone may justify proceeding anonymously. Doe v. Neverson, 820 F. App’x 16 984, 988 (11th Cir. 2020). 17 As a survivor of sex trafficking, Plaintiff’s need for anonymity is compelling. She faces 18 ongoing vulnerability, has a reasonable fear of stigma, and significant harm to employment and 19 social prospects if her identity is publicly disclosed. Plaintiff’s trafficker was physically abusive, 20 threatened her and her family, and had a violent reputation—creating a real risk of retaliation and 21 physical harm (Doc. 62 ¶¶ 91, 96–99.) Thus, the severity of the threatened harm—deep societal 22 stigma and fear of physical harm through retaliation—is severe. These are reasonable fears, given 23 what victims of sex trafficking endure. 24 By contrast, Defendants will suffer no prejudice from Plaintiff’s use of a pseudonym in 25 public filings. S.Y. v. Choice Hotels Int’l, No. 2:20-cv-118-JES-MRM, 2021 U.S. Dist. LEXIS 26 174121, at *21 (M.D. Fla. Sept. 14, 2021) (finding li ttle risk of prejudice to defendants from 27 allowing the use of initials only). Any potential prejudice can be cured by requiring Plaintiff to 28 disclose her identity with appropriate safeguards, such as a protective order, in place. I.B. v. 1 Ganjawala & Kholwad, LLC, Civ. No. 25-37 GBW/SCY, 2025 U.S. Dist. LEXIS 72636 (D.N.M., 2 Jan 13, 2025), at *3–4. 3 Permitting Plaintiff to proceed under a pseudonym will not impair Defendant’s ability to 4 litigate this matter. Plaintiff does not seek to withhold her identity from Defendants. The parties 5 will address the use and dissemination of Plaintiff’s true identity and identifying information, as 6 well as the treatment of other confidential information through a stipulated protective order. 7 Moreover, the public has no significant interest in the disclosure of a trafficking victim’s 8 identity. I.B., 2025 U.S. Dist. LEXIS 72636, at *3. Thus, the harm to Plaintiff of having to 9 disclosure her identity outweighs any public interest in disclosure. Doe v. Sheraton, LLC, No. 1:23- 10 cv-00451-SCY-JMR, 2023 U.S. Dist. LEXIS 116435, at *3–4 (D.N.M. July 3, 2023). Finally, the 11 public interest favors allowing trafficking survivors to proceed under pseudonym, as anonymity 12 encourages victims to come forward while disclosure deters them from reporting sexual crimes. 13 See Doe v. Penzato, 2011 WL 1833007, at *3 (N.D. Cal. May 13, 2011). 14 V. CONCLUSION 15 WHEREFORE, Plaintiff respectfully requests that this Court grant her motion for leave to 16 proceed under the pseudonym “Alice J.” for pretrial proceedings. 17 DATED this 8th day of April, 2026. Respectfully submitted, 18 HILTON PARKER LLC /S/ GEOFFREY C. PARKER 19 GEOFFREY C. PARKER, ESQ. 20 Nevada Bar No. 16952 JONATHAN L. HILTON 21 Nevada Bar No. 16889 HILTON PARKER LLC 22 7658 Slate Ridge Blvd., Reynoldsburg, OH 43068 23 MICHAEL C. KANE, ESQ. 24 Nevada Bar No. 10096 BRADLEY J. MYERS, ESQ. 25 Nevada Bar No. 8857 JOEL S. HENGSTLER, ESQ. 26 Nevada Bar No. 11597 8335 West Flamingo Road 27 Las Vegas, Nevada 89147 28 Attorneys for Plaintiff Alice J. 1 ORDER 2 3 Plaintiffs Unopposed Motion for Leave to Proceed Under a Pseudonym is GRANTED. 4 DATED: April 9, 2026. CS By 6 Craig S. Denney 7 United States Magistrate Judge 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28