Free Motion for Miscellaneous Relief - District Court of Delaware - Delaware

Case 1:05-cv-00424-SLR Document 2 Filed 06/23/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JANE DOE, as the Natural )
Guardian of NANCY DOE, )
a Minor, MARY DOE, a Minor, and , )
a Minor, SUSAN DOE, a Minor, ) C.A. No.:
)
Plaintiffs ) Trial By Jury Dernanded
)
v· J
)
CAPE I-IENLOPEN SCHOOL )
DISTRICT, DANE BRANDENBERGER, )
JANET MAULL, and CINDY )
CUNNINGHAM, )
)
Defendants. )
PLAINTlFFS’ MOTION TO PROCEED ANONYMOUSLY
Plaintiffs hereby move this Court to permit the plaintiffs to proceed in this case
anonymously. Plaintiff is seeking to proceed anonymously because of religious and ethnic
discrimination concerning private matters and because the plaintiffs fear retaliation for having
tiled this lawsuit. In support of this motion the plaintiff states as follows:
l. Plaintiffs fear retaliation from the community against both herself and her
children.
2. The plaintiff and her family have already received threatening phone calls and
acts of violence because of complaints they have made to the school district for the matters
alleged in the complain.
3. The plaintiff is aware of other cases within the State of Delaware, in which the
plaintiffs have brought claims based upon their rights under the First Amendrnent, and for which

Case 1:05-cv-00424-SLR Document 2 Filed 06/23/2005 Page 2 of 2
they have been harassed and threatened, specihcally, a case presently before this Court, Dobric/1
v. Walls, ct.ol,, CA. N0.: 05-l20(JJF).
4. Under appropriate circumstances, the right to proceed in pseudonym has been
recognized. Doe v. Santa Fe bzrlepenclent School District, 530 US. 290, 294 (2000); Doe v.
Frtuz/q 95] FC2d 320, 324 (I1"' Cir. 1992); Doe v. Stegoll, 653 R2:} 186 (5m Cir. 198); Doe v.
P1·oviclentLg'e cmclAccicle11t Insurartoe Co., I 76 ERD., 464, 486 (E.D.Po. 1997).
ABER, GOLDLUST, BAKER 8.c OVER
GARY W. ABER (DSB #754)
702 King Street, Suite 600
P.O. Box 1675
Wilmington, DE 19899
(302) 472-4900
Attorney for Plaintiffs
DATED: June 23, 2005