From a memorandum supporting a motion to permanently seal the entire case in Doe v. Crawford (S.D. Miss.):
Adopting the pseudonym "Jane Doe," Plaintiff filed this case against Defendant Crawford pursuant to 15 U.S.C. § 6851. She alleges Crawford engaged in "revenge porn" by transmitting a sexually intimate photograph of Doe to another man—Doe's current romantic partner—with the intention of embarrassing Doe. In describing her relationship with Crawford, however, Doe states only that they were in a "romantic relationship." In truth, Doe's relationship with Crawford is, and was, more than simply "romantic." …
The Court should seal the record of this case because Crawford's defense necessarily requires him to identify Doe and her relationship to Crawford, as well as disclose intimate details of their relationship…. To defend himself, Crawford must (1) identify Doe and her relationship to Crawford, and (2) disclose intimate details of that relationship in all substantive pleadings, including exhibits, before the Court….
Another procedure will not suffice because 15 U.S.C. § 6851 allows Doe to remain anonymous, yet Crawford must necessarily disclose Doe's identity to defend himself; therefore, sealing the entire case is the only option that allows Doe to litigate her claim anonymously and allows Crawford to defend himself….
