Utah Coalition of La Raza et al v. Herbert et al

Filing 19

MOTION for Leave for Doe Plaintiffs to Proceed Under Pseudonyms filed by Plaintiffs Centro Civico Mexicano, Alicia Cervantes, Coalition of Utah Progressives, Eliana Larios, Latin American Chamber of Commerce, Milton Ivan Salazar-Gomez, Salt Lake City Brown Berets, Service Employees International Union, Utah Coalition of La Raza, Workers United Rocky Mountain Joint Board. (Goddard, Darcy)

Linton Joaquin*
Karen C. Tumlin*
Shiu-Ming Cheer*
Melissa S. Keaney*
NATIONAL IMMIGRATION LAW
CENTER
3435 Wilshire Boulevard, Suite 2850
Los Angeles, California 90010
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Omar C. Jadwat*
Andre I. Segura*
Elora Mukherjee*
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION
125 Broad Street, 18th Floor
New York, New York 10004
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiffs
* Pro hac vice motion pending
+ Counsel for all plaintiffs except SEIU and
Workers’ United

Cecillia D. Wang*
Katherine Desormeau*
AMERICAN CIVIL LIBERTIES
UNION FOUNDATION IMMIGRANTS’
RIGHTS PROJECT
39 Drumm Street
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Darcy M. Goddard (USB No. 13426)
Esperanza Granados (USB No. 11894)
AMERICAN CIVIL LIBERTIES
UNION OF UTAH FOUNDATION, INC.
355 North 300 West
Salt Lake City, Utah 84103
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Bradley S. Phillips*+
MUNGER, TOLLES & OLSON LLP
355 South Grand Avenue
Thirty-Fifth Floor
Los Angeles, CA 90071-1560
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF UTAH
CENTRAL DIVISION
Utah Coalition of La Raza, et al.,
Plaintiffs,
v.
Gary R. Herbert, et al.,
Defendants.

DOE PLAINTIFFS’ MOTION FOR
LEAVE TO PROCEED UNDER
PSEUDONYMS
Case No. 2:11-cv-00401-BCW
Judge: Brooke C. Wells

Plaintiffs Jane Doe #1, John Doe #1, and John Doe #2 (collectively, “Doe Plaintiffs”), by
and through counsel, respectfully seek leave to proceed under pseudonyms in this action. This
motion is supported by (i) a Memorandum of Points and Authorities and (ii) Declarations of
Darcy Goddard, Theresa Martinez, and Octavio Villalpando, all of which are filed concurrently
herewith. The motion is also supported by declarations of each of the Doe Plaintiffs; counsel
will shortly file a motion under DUCiv R 5-2(a) requesting permission to file those declarations
under seal, and will file them promptly on receipt of an order from the Court authorizing them to
do so under seal.
All three Doe Plaintiffs should be permitted to pursue this litigation under pseudonyms.
As detailed in Plaintiffs’ Memorandum of Points and Authorities, if the Doe Plaintiffs’ identities
and participation in this lawsuit were to become public, there would be an increased risk that
they or their family members would be subjected to unconstitutional detention by the police, the
initiation of removal proceedings or other adverse immigration consequences, and public
hostility, harassment, and even violence.
For these and other reasons, the Doe Plaintiffs respectfully request that this Court grant
their motion to proceed under pseudonyms.

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Dated: May 4, 2011

Respectfully submitted,
/s/ Katherine Desormeau
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION, IMMIGRANTS’
RIGHTS PROJECT
/s/ Shiu-Ming Cheer
NATIONAL IMMIGRATION LAW CENTER
/s/ Darcy M. Goddard
AMERICAN CIVIL LIBERTIES UNION
OF UTAH FOUNDATION, INC.
/s/ Elora Mukherjee
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION, RACIAL JUSTICE PROGRAM
/s/ Bradley S. Phillips
MUNGER, TOLLES & OLSON LLP

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