govinfo:USCOURTS-dcd-1_26-cv-01856-0

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UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 
 
WARREN, et al., 
 
 Plaintiffs, 
 
 v. Civil Action No. 26-1856 
ISLAMIC REPUBLIC OF IRAN, 
 
Defendant. 
 
 
 
 
MEMORANDUM OPINION AND ORDER 
 
 Victims (and their family members) of a bomb attack in Afghanistan’s diplomatic quarter 
by the Taliban and its affiliates bring this action against Iran for its support of those 
organizations. See ECF No. 1 (Compl.), ¶¶ 38–43. The Complaint names a number of Plaintiffs. 
Id. at 1–2. Others, however, seek to proceed pseudonymously, citing concerns of “reprisal[]” 
targeted at Plaintiffs who remain in or have family members living in Afghanistan. See ECF No. 
2 (Mot. Pseudo), ¶ 4. While Plaintiffs’ Motion and supporting memorandum are scant on detail, 
they eke out a showing sufficient for the Court to grant at this early stage. See LCvR 40.7(f) 
(providing that Chief Judge shall “hear and determine . . . motion[s] to file a pseudonymous 
complaint”). 
I. Legal Standard 
Generally, a complaint must identify the plaintiffs. See Fed. R. Civ. P. 10(a); LCvR 
5.1(c)(1). This identification requirement reflects the “presumption in favor of disclosure [of 
litigants’ identities], which stems from the ‘general public interest in the openness of 
governmental processes,’ and, more specifically, from the tradition of open judicial 
proceedings.” In re Sealed Case, 931 F.3d 92, 96 (D.C. Cir. 2019) (quoting Wash. Legal 

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Found. v. U.S. Sentencing Comm’n, 89 F.3d 897, 899 (D.C. Cir. 1996)). A party moving to 
proceed pseudonymously thus “bears the weighty burden of both demonstrating a concrete need 
for such secrecy[] and identifying the consequences that would likely befall it if forced to 
proceed in its own name.” In re Sealed Case, 971 F.3d 324, 326 (D.C. Cir. 2020). As a result, 
the court must “‘balance the litigant’s legitimate interest in anonymity against countervailing 
interests in full disclosure’” by applying a “flexible and fact driven” balancing test. Id. (quoting 
In re Sealed Case, 931 F.3d at 96). That test assesses “five non-exhaustive factors”: 
(1) whether the justification asserted by the requesting party is 
merely to avoid the annoyance and criticism that may attend any 
litigation or is to preserve privacy in a matter of [a] sensitive and 
highly personal nature; 
(2) whether identification poses a risk of retaliatory physical or 
mental harm to the requesting party or[,] even more critically, to 
innocent non-parties; 
(3) the ages of the persons whose privacy interests are sought to be 
protected; 
(4) whether the action is against a governmental or private party; 
and relatedly, 
(5) the risk of unfairness to the opposing party from allowing an 
action against it to proceed anonymously. 
 
Id. at 326–27 (quoting In re Sealed Case, 931 F.3d at 97) (first alteration in original). 
II. Analysis 
Plaintiffs’ Motion hinges on their (or their family members’) residence in Afghanistan. 
See Mot. Pseudo, ¶¶ 3–6; see also ECF No. 2-1 (Mem. Supp.) at 2–3 (“[T]hose individuals 
without family living in Afghanistan have not requested anonymity.”). They fear that a “serious 
risk of physical harm to themselves and their family” would result from disclosing their true 
names because the Taliban — which allegedly perpetrated the underlying bombing — “remains 
in control of Afghanistan and hostile to those who previously opposed the group.” Mem. Supp. 
at 2. 

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Plaintiffs’ fear of retaliation swings the first two factors towards pseudonymity. Where 
revelation of a plaintiff’s identity would trigger a risk of retaliation from a foreign government, 
courts have held that the resulting safety interests warrant proceeding pseudonymously. See, 
e.g., Doe v. Islamic Republic of Iran, No. 26-1002, ECF No. 3 (Mem. Op.) at 3. Plaintiffs living 
in or with family members residing in Afghanistan do not wish to shield their names “merely to 
avoid the annoyance and criticism that may attend any litigation.” In re Sealed Case, 971 F.3d at 
326. They fear reprisal by their own Taliban-controlled government. See Mot. Pseudo, ¶¶ 3–4. 
The basis for that fear? The Taliban’s prior targeting and bombing of Plaintiffs and their family 
members because of their employment by the United States. Id., ¶ 3. The Court finds it 
conceivable that Plaintiffs would face physical threats of the same type they have previously 
experienced. It thus concludes that concealing the Afghanistan-resident Plaintiffs’ identities 
protects their safety interests and mitigates the risk of retaliation they face from their connection 
with the United States. Cf. J.K.A. v. United States, 2023 WL 12248425, at *2 (D.D.C. Aug. 10, 
2023) (second factor favors pseudonymity when plaintiffs faced “threats of retaliation” from and 
past violence by foreign government); Doe v. U.S. Dep’t of State, 2015 WL 9647660, at *3 
(D.D.C. Nov. 3, 2015) (permitting pseudonymity where plaintiff “plausibly shows his life will be 
in greater danger if his name is publicly connected to a complaint revealing his help” to U.S.). 
The third factor 
 slightly supports Plaintiffs. This factor calls for pseudonymity when the 
privacy interests or safety of a minor are implicated — even for adult plaintiffs whose identities 
are intertwined with their children’s. See, e.g., Doe v. Blinken, No. 23-2997, ECF No. 3 (Mem. 
Op.) at 4 (D.D.C. Oct. 13, 2023) (“To the extent that revealing Plaintiff’s identity would also 
reveal the identities of his four minor children, proceeding pseudonymously would be 
appropriate.”). Here, “some of the family members of the victims [of the bombing] are minors” 

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whose safety in Afghanistan would also be implicated by disclosure. See Mem. Supp. at 3. 
Some of the Plaintiffs attempting to proceed pseudonymously are themselves the minor children 
of one of the victims. See Compl., ¶¶ 12, 14–16. While the minor Plaintiffs have the right to 
proceed pseudonymously under Federal Rule of Civil Procedure 5.2(a)(3), disclosure of their 
close family members’ names would make them “easily identifiable and threaten [their] 
confidentiality.” I.G.I. v. Noem, 2025 WL 4083339, at *1 (D.D.C. Nov. 18, 2025). The safety 
interests of both the minor Plaintiffs and the non-plaintiff children of adult Plaintiffs tilt this 
factor towards pseudonymity. 
The De fendant’s identity (factor four) militates towards pseudonymity because Plaintiffs 
sue a foreign government seeking individualized relief. See Compl. at 26–30; Doe v. Blinken, 
No. 24-1629, ECF No. 3 (Mem. Op.) at 5 (D.D.C. June 11, 2024) (“When a plaintiff requests 
individualized relief against a government defendant[,] . . . the fourth factor favors 
pseudonymity.”) (citation omitted). Pseudonymity is more palatable where — as here — a 
plaintiff seeks “to vindicate merely his individual right” against a government entity than where 
litigants attempt to alter the operation of a program or regulation moving forward. T.F. v. District 
of Columbia, No. 23-3612, ECF No. 4 (Mem. Op.) at 4 (D.D.C. Dec. 7, 2023). 
Nor would Plaintiffs’ pseudonymity prejudice Defendant: Plaintiffs have agreed to reveal 
their true names under seal. See Mot. Pseudo at 2. This Court has repeatedly held that the fifth 
factor is “not implicated” under such circumstances. In re Sealed Case, 971 F.3d at 326 n.1; see 
also R.A. v. Islamic Republic of Iran, No. 23-2606, ECF No. 4 (Mem. Op.) at 5 (D.D.C. Sept. 12, 
2023) (fifth factor supports pseudonymity because “[w]hile this is not a case in which Defendant 
knows their identities already, Plaintiffs have offered to disclose them under seal and have not 
asked to do so ex parte”). What is more, Iran rarely appears in suits against it brought — as this 

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one is — under the Foreign Sovereign Immunities Act. See Mem. Supp. at 3. Should it follow 
that pattern here, Iran “would not be prejudiced by” the withholding of Plaintiffs’ identities from 
the public. Shargi v. Islamic Republic of Iran, No. 26-1193, ECF No. 6 (Mem. Op.) at 4 (D.D.C. 
May 1, 2026). If Iran does appear in this case, moreover, it may seek reconsideration by the 
District Judge to whom the case is randomly assigned. Id. at 5. 
Without discernible prejudice to Defendant and given the colorable risk of retaliatory 
harm Plaintiffs face, pseudonymity is warranted at this juncture. The Court accordingly 
ORDERS that: 
1. Plaintiffs’ [2] Motion for Leave to File Under Pseudonym is GRANTED, subject to 
any further consideration by the United States District Judge to whom this case is 
randomly assigned; 
2. All parties shall use the pseudonyms listed in the Complaint in all documents filed in 
this action; and 
3. Within fourteen days of this Order, Plaintiffs shall file: 
i. A pseudonymous version of their [2] Motion and any attachments as a Notice to 
the Court on the public docket; and 
ii. A sealed declaration containing their real names and residential addresses. 
 
/s/ James E. Boasberg 
JAMES E. BOASBERG 
Chief Judge 
Date: June 3, 2026 
 
 

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