The Volokh Conspiracy

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Make Sure the PDF Title of Your Document Doesn't Include Confidential Information (Such as a Pseudonymous Plaintiff's Name)

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I recently ran across a case in which the plaintiff was a John Doe—but when I downloaded the Complaint, I saw the plaintiff's name as part of the tab name in my browser. It appears that the PDF for the filing was created with a title that contained the plaintiff's name (you can see a PDF document's title in Adobe by clicking ctrl-D). That in turn presumably stemmed from the original word processing document containing that title, maybe from a time before the plaintiff's lawyer thought the case should be litigated under a pseudonym.

In any event, a tip: If you're filing a document in a pseudonymized case, or in a case you want pseudonymized, check the PDF to make sure that the party's name doesn't appear in the title.