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The Volokh Conspiracy Mostly law professors | Sometimes contrarian | Often libertarian | Always independent About The Volokh Conspiracy D Sealing Kinda Sus EUGENE VOLOKH | 2.14.2022 8:01 AM From Judge Ronald A GuzmÃ¡n's decision in Doe v. Sandler(N.D. Ill. 2011), which just came across -as I read it, the judge began the case being open not just to pseudonymity but to sealing (the original TRO, for instance, is sealed, which is very rarely done for court orders), but ultimately seemed tO sour on that: Plaintiff, Jane Doe, has filed a Verified Complaint asserting a claim for invasion of privacy based on public disclosure of private facts under Illinois law. In summary, plaintiff, a self-described married woman, civic and church leader, became embroiled in an affair. During the course of the affair she and her partner made photographic and video recordings of an intimate sexual nature. These recordings subsequently fell into the hands of her sexual partner's "girlfriend" who has threatened to publish the video and photographic evidence of their sexual conduct in different ways, including through the Internet for all the world to see, expose her behavior to her friends and social and religious groups, and has even attempted to extort money from plaintiff, her husband and the parties' mutual sexual partner -whose identity plaintiff also seeks to protect by using the pseudonym "Richard Roe."