UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

 

JANE DOE, an individual Michigan resident 

filing anonymously under a fictitious name, 

 Plaintiff, 

 Case No. 2:15-cv-10724 

v. Hon. Stephen J. Murphy, III 

 Mag. Elizabeth A. Stafford 

MAMOUN DABBAGH, M.D., 

 Defendant. 

_________________________________________________________________ 

Nakisha N. Chaney (P65066) 

NACHT, ROUMEL, SALVATORE, 

BLANCHARD & WALKER, P.C. 

Attorney for Plaintiff 

101 N. Main Street, Ste. 555 

Ann Arbor, Michigan 48104 

(734) 663-7550 

________________________________________________________/ 

PLAINTIFF’S MOTION TO PROCEED WITH PSEUDONYMOUS 

STATUS 

Plaintiff is a human trafficking survivor who was beaten, raped and provided 

to others for sex and labor during her ordeal. (Ex. A, Dckt No. 1 at ¶¶17-18). 

Plaintiff’s trafficker, Mark White, used multiple coercive means to control Plaintiff, 

including forcing her to take psychotropic medications such as Adderall. (Id. at ¶¶18, 

49-57). Adderall is a controlled stimulant that can alter a person’s mood and activity. 

2:15-cv-10724-SJM-EAS Doc # 4 Filed 03/06/15 Pg 1 of 6 Pg ID 19
2 

(Id. at ¶¶25-28). It is classified by the DEA as a Schedule II drug with addictive 

qualities and a high risk of dependence. (Id. at ¶¶25-26). 

Defendant Mamoun Dabbagh is a licensed psychiatrist who, at the request of 

Plaintiff’s trafficker, wrote prescriptions for Adderall and Celexa in Plaintiff’s name, 

knowing that White intended to have Plaintiff take the pills. (Id. at ¶¶41-55, 70, 

71(e)). White used the pills and other drugs to facilitate his ability to control and 

traffic Plaintiff. (Id. at ¶57). In doing so, he subjected Plaintiff to multiple acts of 

sexual and physical degradation, including raping her and forcing her to provide 

massage and sexual services to other men. (Id. at ¶¶17-18) 

In May 2013, Plaintiff escaped and reported his crimes. (Id. at ¶63). When 

law enforcement arrived at his home with a warrant, White committed suicide. (Id. 

at ¶¶64-65). On February 26, 2015, Plaintiff filed a complaint against Defendant 

Dabbagh, asserting that he knowingly benefitted from participation in a venture 

which he knew or should have known involved trafficking. (Id. at ¶68). Plaintiff 

seeks to proceed under pseudonymous status as this case will involve the disclosure 

of highly intimate facts with great potential to stigmatize and embarrass Plaintiff. 

ARGUMENT 

Federal Rule of Civil Procedure 10(a) “requires plaintiffs to disclose their 

names in the instrument they file to commence a lawsuit.” Fed. R. Civ. P. 10(a). 

However, there “is precedent for departing from procedural custom...to 

2:15-cv-10724-SJM-EAS Doc # 4 Filed 03/06/15 Pg 2 of 6 Pg ID 20
3 

accommodate a plaintiff’s asserted need to proceed anonymously through the use of 

a fictitious name.” Doe v. Stegall, 653 F.2d 180, 185 (5th Cir. 1981). In considering 

whether to allow a plaintiff to proceed anonymously, courts generally weigh 

“considerations calling for maintenance of a party’s privacy against the customary 

and constitutionally-embedded presumption of openness in judicial proceedings.” 

Stegall, 653 F.2d at 186. The Sixth Circuit has emphasized four considerations to 

weigh in determining whether to allow plaintiffs to proceed pseudonymously. They 

include: 

(1) whether the plaintiffs seeking anonymity are suing to challenge 

governmental activity; (2) whether prosecution of the suit will compel 

the plaintiffs to disclose information "of the utmost intimacy"; (3) 

whether the litigation compels plaintiffs to disclose an intention to 

violate the law, thereby risking criminal prosecution; and (4) whether 

the plaintiffs are children. 

Doe v. Porter, 370 F.3d 558, 560 (6th Cir. 2004). 

 Pseudonymous status is warranted here because Plaintiff will (and has through 

the complaint) disclosed information of the “utmost intimacy.” This case involves 

multiple acts of rape and sexual assault arising from and related to Plaintiff’s 

subjection to human trafficking. Sexual abuse, particularly of the degree and severity 

suffered by Plaintiff during the course of being trafficked, is certainly a matter of 

“the utmost intimacy,” and thus pseudonymous status is appropriate. See, e.g, Doe 

v. Penzato, No. CV10-5154, 2011 U.S. Dist. LEXIS 51681 (N.D. Cal. May 13, 2011) 

(granting motion to proceed anonymously to plaintiff making allegations of sex 

2:15-cv-10724-SJM-EAS Doc # 4 Filed 03/06/15 Pg 3 of 6 Pg ID 21
4 

trafficking and sexual assault), Ex. B; Doe v. Blue Cross & Blue Shield, 112 F.3d 

869, 872 (7th Cir. 1997) (“[F]ictitious names are allowed when necessary to protect 

the privacy of . . . rape victims, and other particularly vulnerable parties or 

witnesses.”); Doe No. 2 v. Kolko, 242 F.R.D. 193, 195 (E.D.N.Y. 2006) (granting 

pseudonymous status in part because “the public generally has a strong interest in 

protecting the identity of sexual assault victims so that other victims will not be 

deterred from reporting such crimes”); Roe v. St. Louis Univ., No. 4:08CV 1474, 

2009 U.S. Dist. LEXIS 27716 at *13-14 (E.D. Mo. Apr. 2, 2009) (granting 

anonymous status to rape victim), Ex. C. 

CONCLUSION 

 Plaintiff was subjected to multiple acts of sexual degradation and violence 

while being trafficked. Thus, as evident by the complaint, this litigation will involve 

the exposure of facts that are intensely intimate, with great potential to cause Plaintiff 

to suffer public stigma or embarassment. Plaintiff therefore requests permission to 

proceed under a pseudonym. Plaintiff has not sought concurrence as Defendant has 

not yet filed an appearance. 

 

2:15-cv-10724-SJM-EAS Doc # 4 Filed 03/06/15 Pg 4 of 6 Pg ID 22
5 

Respectfully submitted, 

 NACHT, ROUMEL, SALVATORE, 

 BLANCHARD & WALKER, P.C. 

 

Dated: March 6, 2015 /s/ Nakisha N. Chaney 

 Nakisha Chaney (P65066) 

 Attorney for Plaintiff 

 101 N. Main Street, Suite 555 

 Ann Arbor, Michigan 48104 

 (734) 663-7550 

 nchaney@nachtlaw.com 

 

2:15-cv-10724-SJM-EAS Doc # 4 Filed 03/06/15 Pg 5 of 6 Pg ID 23
6 

CERTIFICATE OF SERVICE 

 I hereby certify that on March 6, 2015, I electronically filed the foregoing 

paper with the Clerk of the Court using the ECF system and served a copy upon 

Defendant Dabbagh at his last known address by first-class mail. 

Respectfully submitted, 

 NACHT, ROUMEL, SALVATORE, 

 BLANCHARD & WALKER, P.C. 

 

Dated: March 6, 2015 /s/ Nakisha N. Chaney 

 Nakisha Chaney (P65066) 

 Attorney for Plaintiff 

 101 N. Main Street, Suite 555 

 Ann Arbor, Michigan 48104 

 (734) 663-7550 

 nchaney@nachtlaw.com 

2:15-cv-10724-SJM-EAS Doc # 4 Filed 03/06/15 Pg 6 of 6 Pg ID 24