STIPULATION AND [PROPOSED] ORDER TO ALLOW PLAINTIFFS TO PROCEED ANONYMOUSLY

JAMES L. ROBART, District Judge.

Plaintiffs John Doe, Jane Doe, Jack Doe, Jason Doe, Julia Doe, Joseph Doe and James Doe (collectively "Doe Plaintiffs") and Defendants Donald Trump, President of The United States; U.S. Department of State; Rex Tillerson, Secretary of State; U.S. Department of Homeland Security; John Kelly, Secretary of Homeland Security; U.S. Customs and Border Protection; Kevin McAleenan, Acting Commissioner of U.S. Customs and Border Protection; and Michele James, Field Director of the Seattle Field Office of U.S. Customs and Border Protection (collectively "Defendants"), through their undersigned counsel of record, hereby stipulate and agree as follows:

Doe Plaintiffs filed a Class Action Complaint for Declaratory and Injunctive Relief on February 7, 2017 and a First Amended Class Action Complaint for Declaratory and Injunctive Relief on March 14, 2017.

Doe Plaintiffs represent to the Court that they filed their complaints under pseudonyms because, inter alia, of widespread reports of the increases in anti-Muslim harassment around the country, including here in Washington. Doe Plaintiffs fear similar harassment if they were to be publicly named in this lawsuit.

At this time, Defendants do not oppose Plaintiffs' motion to proceed under pseudonyms. However, Defendants reserve the right at a future date either to request that the Court enter a protective order to provide access to Defendants, or to move to unseal the identities of one or more of the pseudonymous Plaintiffs. Although Defendants do not have a need at this time for the pseudonymous Plaintiffs to reveal their identity or otherwise be publicly disclosed, future litigation events — including, but not limited to, Defendants' need to respond to any motion for class certification — may require this Court to revisit the issue.

WHEREAS,

IT IS HEREBY STIPULATED by and among Doe Plaintiffs and Defendants, subject to the Court's approval, as follows:

Doe Plaintiffs shall be allowed to proceed under pseudonyms in this action at this time.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.