Apropos the "cat out of the bag" objection to sealing or pseudonymity, I thought I'd note last month's P.F. v. M.B. (by Queens County, N.Y. judge Scott Dunn), which offers an example of the contrary approach. I'm not saying the P.F. result is correct, but I thought it worth noting:
For a period of approximately one year, Plaintiff and Defendant M.B. allegedly were engaged in a serious romantic relationship while Defendant M.B. was married to … Defendant Calcetas …. Plaintiff also alleges that Defendants, in concert or one at the direction of the other, and without Plaintiff's consent, disseminated intimate photographs and videos of Plaintiff to Plaintiff's mother, business associates, and to a third party who had previously agreed to purchase Plaintiff's business. Defendants allegedly also used social media and emails to message and threaten Plaintiff, all of which allegedly caused damage to Plaintiff….
Plaintiff had sought pseudonymity from when she filed the case, in March 2023, and got it in August 2023; defendant M.B. had been named in the filings throughout that time. Then in April 2025, defendant counterclaimed, alleging unlawful disclosure of his intimate images, as well as "battery through poisoning/non-consensual drugging." And in July 2025, defendant moved to be pseudonymized in the file. No problem, said the court, in part because the pseudonymization would only be for future filings:
