Jane Doe v. G6 Hospitality, LLC et al.

• Court: District Court, W.D. Washington
• Decided: December 3, 2025
• Docket: 2:25-cv-00358
• Status: Unknown

Opinion

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3 4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 JANE DOE, CASE NO. 2:25-cv-00358-JNW 8 Plaintiff, ORDER GRANTING IN PART 9 PLAINTIFF’S MOTION TO PROCEED v. UNDER A PSEUDONYM 10 G6 HOSPITALITY, LLC et al., 11 Defendants. 12 13 Plaintiff brings claims under the Trafficking Victims Protection 14 Reauthorization Act, alleging she was sex trafficked at Defendants’ hotel properties 15 and that Defendants knew or should have known of the trafficking and benefited 16 from it. Dkt. No. 1. She moves to proceed under the pseudonym “Jane Doe” because 17 she fears her traffickers and their associates will retaliate against her—including 18 by harming, killing, or forcing her back into trafficking—if they learn she is 19 pursuing this lawsuit, and because public disclosure would cause humiliation and 20 shame given the sensitive nature of the crimes she suffered. Dkt. No. 52 at 2–3. 21 Two defendants responded to her motion, not to oppose, but to ask that 22 Plaintiff proceed under her initials to avoid confusion with other litigation. Dkts. 23 1 Nos. 53, 54. Plaintiff did not file a reply or otherwise object to this request. 2 To protect the public’s interest in the open administration of justice, parties

3 must use their real names during litigation. See Fed. R. Civ. P. 10(a). But “[i]n this 4 circuit, we allow parties to use pseudonyms in the ‘unusual case’ when 5 nondisclosure of the party’s identity ‘is necessary ... to protect a person from 6 harassment, injury, ridicule or personal embarrassment.’” Does I Thru XXIII v. 7 Advanced Textile Corp., 214 F.3d 1058, 1067–68 (9th Cir. 2000) (quoting United 8 States v. Doe, 655 F.2d 920, 922 n.1 (9th Cir. 1981)). A party may proceed

9 anonymously “when the party’s need for anonymity outweighs prejudice to the 10 opposing party and the public’s interest in knowing the party's identity.” Id. at 11 1068. 12 “To determine whether to allow a party to proceed anonymously when the 13 opposing party has objected, a district court must balance five factors: ‘(1) the 14 severity of the threatened harm, (2) the reasonableness of the anonymous party's 15 fears, ... (3) the anonymous party's vulnerability to such retaliation,’ (4) the

16 prejudice to the opposing party, and (5) the public interest.” M.L. v. craigslist, No. 17 3:19-6153-BHS-TLF, 2020 WL 8639345, at *1 (W.D. Wash. July 8, 2020) (quoting 18 Doe v. Kamehameha Schools/Bernice Pauahi Bishop Est., 596 F.3d 1036, 1042-45 19 (9th Cir. 2010)). 20 Plaintiff is a survivor of sex trafficking. Her motion details serious physical 21 abuse, including being shot and beaten, during years of exploitation. Plaintiff fears

22 retaliation from her traffickers and their associates. Courts routinely permit 23 trafficking survivors to proceed anonymously given the severity of harm they have 1 suffered and the reasonable fear of retaliation. See, e.g., M.L. v. craigslist, 2020 WL

9 8639345, at *1-2; B.M. v. Wyndham Hotels & Resorts, Inc., No. 20-CV-00656-BLF, 3 2020 WL 4368214, at *9 (N.D. Cal. July 30, 2020). Defendants do not oppose, and

4 the Court finds good cause exists here.

5 The Court agrees with Defendants, however, that proceeding under initials

|/rather than “Jane Doe” will reduce confusion with similar cases.

7 Accordingly, the Court ORDERS as follows:

8 1. Plaintiff Jane Doe’s motion is granted in part. 9 2. Plaintiff may proceed under a pseudonym in this action using only the

10 first initials of her first and last name.

11 3. Plaintiff must file a Notice with the Court within ten (10) days of this

12 order identifying her initials.

13 Dated this 3rd day of December, 2025.

14 Z Le— 15 Jamal N. Whitehead United States District Judge 16 17 18 19 20 21 22 23