A plaintiff may apply to the court for leave to proceed by a fictitious name if privacy concerns outweigh the First Amendment interest in public access to judicial proceedings.  Here, the employee on whose behalf DFEH sued for employment discrimination said that revealing his identity and caste would subject him and his family to discrimination and jeopardize their safety in India.  The decision holds that potential harm to the plaintiff or his family is a reason to permit suit by fictitious name even if the harm will potentially occur in a foreign country rather than in the US.