Participated in an amicus brief (with other amici) filed with the U.S. Court of Appeals for the Eleventh Circuit in National Rifle Association v. Bondi. This case questions whether civil litigants challenging the constitutionality of a state statute may do so anonymously because they fear harassment. The brief argues that permitting pseudonymous plaintiffs impinges the public’s First Amendment and common law rights of access to court proceedings. The use of pseudonyms may lead to additional, significant restrictions on the public’s presumptive right of access to civil proceedings and documents. The brief concludes that this court should affirm the order of the district court denying the motion to proceed under pseudonyms.