Unreported / Non-Citable
Background
Plaintiff Jane Doe 1 initiated this action on October 28, 2025, alleging that Defendants G6 Hospitality, LLC, and others are liable under the Trafficking Victims Protection Reauthorization Act (TVPRA) and common law for their role in her alleged sex trafficking from July 2018 to August 2020 at properties owned, operated, or controlled by Defendants. Minor Plaintiff Jane Doe 2, the biological daughter of Jane Doe 1, joined the action on January 12, 2026. Plaintiffs allege that Jane Doe 1 became pregnant with Jane Doe 2 during the trafficking period and was forced to engage in commercial sex acts until the day of delivery, resulting in an emergency cesarean section. Jane Doe 2 nearly died during birth and was later diagnosed with cerebral palsy with incomplete quadriplegia, which Plaintiffs allege resulted from the trafficking. Both Plaintiffs filed motions to proceed under pseudonyms (Doc. Nos. 2 and 22), and no party filed an opposition to either motion.
The court addressed the dispute on the record described in the opinion. Allegations are presented as allegations, and the procedural posture controls what the ruling establishes. The result therefore turns on the motion and evidence actually before the court, not on a final resolution of every claim in the underlying litigation overall.
The Court’s Holding
The court granted both motions to proceed under pseudonyms. For Jane Doe 1, the court found good cause based on the nature of the sex trafficking allegations, which created a reasonable fear of retaliatory physical or mental harm from her traffickers if her identity were made public. This fear outweighed the public’s interest in knowing her identity, and Defendants would not be prejudiced because they could ascertain her identity through discovery and had not opposed the motion. For Jane Doe 2, the court found good cause based on her status as a minor, the highly sensitive and personal nature of the circumstances surrounding her birth and medical condition, and the risk of retaliation from her mother’s traffickers. The court noted that Local Rule 140(a)(i) requires minors to proceed anonymously when their specific identity is not necessary to the action. The court also found minimal prejudice to Defendants because Plaintiffs are willing to disclose identifying information under an appropriate protective order. The court ordered all parties to use the pseudonyms “Jane Doe 1” and “Jane Doe 2” in all future filings and prohibited disclosure of Plaintiffs’ true names except by court order.
The ruling’s procedural posture and stated remedy are important limits on its reach. The summary therefore describes only the relief actually ordered or recommended and does not convert allegations into findings.
Key Takeaways
- The court applied the Ninth Circuit’s balancing test from Does I thru XXIII v. Advanced Textile Corp., 214 F.3d 1058 (9th Cir. 2000), weighing the party’s need for anonymity against prejudice to the opposing party and the public’s interest in open courts.
- For Jane Doe 1, the court found that allegations of sex trafficking involving physical force, intimidation, coercion, and threats established a reasonable fear of retaliatory harm, satisfying the first category of cases where pseudonyms are permitted (risk of retaliatory physical or mental harm).
- For Jane Doe 2, the court emphasized her status as a minor as weighing heavily in favor of anonymity, citing Local Rule 140(a)(i) and precedent establishing that minors may proceed anonymously. The court also recognized the privacy interests in shielding intimate details of her birth, medical condition, and her mother’s victimization.
- The court found no prejudice to Defendants for either Plaintiff, noting Defendants’ appearance without opposition, the availability of discovery to ascertain identities, and Plaintiffs’ willingness to disclose identities under a protective order.
- The court cited multiple recent district court decisions within the Ninth Circuit uniformly allowing plaintiffs alleging sexual assault or trafficking to proceed under pseudonyms, reinforcing a consistent practice in such cases.
Why It Matters
This order reinforces the strong presumption in the Eastern District of California and the Ninth Circuit that plaintiffs alleging sex trafficking and sexual assault may proceed under pseudonyms to protect against retaliatory harm and preserve privacy, particularly for minor children. The decision highlights the court’s willingness to grant pseudonym motions at an early stage when defendants do not oppose and when the allegations involve severe trauma and ongoing safety risks. The ruling also underscores the procedural protection afforded to minors under Local Rule 140(a)(i) and the court’s recognition that the public’s interest in open proceedings is satisfied by the availability of judicial decisions without disclosure of victims’ identities. The order’s prohibition on disclosing true names except by court order provides a clear enforcement mechanism for the pseudonym protection.
For California practitioners, the order supplies a concrete application of the governing standard and a reminder to preserve the procedural steps and evidentiary record on which relief depends.