Having previously won a ruling that a woman suing a vice president with Paramount Pictures Corp. and parent company Paramount Global must use her true name in future pleadings or justify her bid to remain anonymous, studio attorneys are now asking a judge to officially deny the plaintiff’s request.
The plaintiff is currently identified only as Jane Doe in the Los Angeles Superior Court lawsuit, which alleges sexual harassment, hostile work environment, negligence, negligent retention, retaliation and intentional infliction of emotional distress. The plaintiff also alleges that the vice president, Patrick Smith, was her supervisor and also disparaged other female employees.
Judge Virginia Keeny issued her identification ruling in May and is scheduled to issue a final ruling on July 14. The judge also dismissed Doe’s retaliation and gender discrimination causes of action and said that the plaintiff will have to shore up other parts of her complaint against Smith for those allegations to remain part of her lawsuit. Doe was given 60 days to file an amended complaint.
On Tuesday, attorneys for the two Paramount entities filed court papers with Keeny noting her May ruling and stating that a 2025 state appellate court decision established that litigating by pseudonym is permitted only in the rarest of circumstances and that a plaintiff’s “conclusory fears of reputational and professional harm” — even in a case involving allegations of sexual harassment — do not overcome the public’s “substantial and presumptive interest in knowing who invokes its courts.”
The Paramount lawyers further noted that Doe’s sworn declaration describes her alleged anxiety about being publicly associated with her lawsuit, the stigma of being in a “relationship-driven” industry and a general concern that disclosure would set back her recovery.
“Those concerns are real and (the Paramount entities) do not minimize them,” the studio attorneys state in their court papers while adding that they are nonetheless the very harms the appellate court held insufficient because they apply to many litigants.
According to the suit filed in July 2025, Doe was repeatedly made to feel “self-conscious, embarrassed, intimidated, dehumanized … and extremely uncomfortable at work each day at work, as a result of (Smith’s) conduct and behavior and defendant … Paramount Pictures’ failure to prevent such conduct.”
Doe was hired in 2017 and reported directly to Smith, who two years later transferred her to XYi Design, a Paramount vendor that provided marketing and design services. While doing work for XYi, Doe continued to be at the Paramount office with the vice president as her supervisor, the suit further contends.
According to Doe, Smith “persistently subjected plaintiff Doe to his intrusive and unwelcome gaze, leering at her body and making inappropriate sexual remarks about her figure. His offensive scrutiny compelled plaintiff to drape a sweater around her waist in a desperate attempt to shield herself from his predatory eyes.”
However, Doe’s efforts were mostly ineffective against Smith’s “relentless” misconduct, the suit alleges. He sent her numerous texts with a sexual and often vulgar tone, including “I really love you, please know that,” the suit states.