Paramount Pictures Corp. and parent company Paramount Global are asking a judge to dismiss a woman’s sexual harassment lawsuit for failing to file an amended complaint using her true name, but the plaintiff says in her court papers, obtained Sunday, that she wants to remain anonymous for good reason.
Beginning in 2017 and continuing without pause until February 2025 — nearly eight years — the plaintiff was “subjected to a relentless campaign of sexual harassment, humiliation and exploitation by my direct supervisor, defendant Patrick Smith, a vice president at Paramount,” the woman identified only as Jane Doe states in a sworn declaration filed Thursday with Los Angeles Superior Court Judge Virginia Keeny.
“Proceeding anonymously is the only way I can realistically participate in this lawsuit without sacrificing the fragile but essential sense of safety and privacy that my mental health and ongoing treatment depend upon,” Doe says.
Smith “bombarded me daily with sexual compliments, degrading comments and unwanted advances,” Doe further says. “He leered at my body in the workplace, forcing me to drape a sweater around myself in a desperate attempt to shield myself from his predatory gaze. He sent me a continuous stream of sexually explicit and deeply demeaning messages.”
The prospect of being publicly named in connection with her allegations causes Doe severe emotional distress, she says.
“The thought that my full name could become permanently searchable online — inextricably linked to the graphic sexual text messages Smith sent me, to the details of his daily harassment of my body and to the retaliation I suffered for resisting –fills me with profound dread,” Doe further says.
Doe adds that she constantly worries about friends, family, current and future colleagues and potential employers finding and reading about her alleged experiences.
“When I imagine my name appearing in case captions and media coverage, I experience symptoms of acute anxiety and panic, including difficulty breathing, racing heartbeat and complete inability to sleep. This is not a hypothetical concern. It is a fear I live with daily.”
Doe’s lawsuit alleges sexual harassment, hostile work environment, negligence, negligent retention, retaliation and intentional infliction of emotional distress. The plaintiff also alleges that Smith also disparaged other female employees.
Smith filed a motion in April asking that Doe be required to use her real name in future pleadings. Keeny ruled in mid-July that Doe failed to establish that any general privacy interest outweighed the public’s right of access. Keeny ordered the plaintiff to file an amended complaint with her real name by Aug. 13.
The deadline date has come and passed and now Doe’s lawsuit should be dismissed, according to the Paramount attorneys’ court papers filed with the judge in advance of a December hearing. Doe’s failure to file a revised complaint with her true identity is willful because the judge’s order could not have been clearer and compliance is entirely within Doe’s control, according to the Paramount attorneys.
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.