What is the test for abuse of discretion in a motion where a sealed plaintiff is denied access to an anonymous pleading?

MultiRegion, United States of America

The following excerpt is from Anonymous v. Medco Health Solutions, Inc., No. 13-4645-cv (2nd Cir. 2014):

Because a district court's ruling on the appropriateness of an anonymous pleading is a "factor-driven balancing inquiry" that requires discretion in "weighing competing interests," we review for abuse of discretion. Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 190 (2d Cir. 2008). A district court abuses its discretion when "(1) its decision rests on an error of law (such as application of the wrong legal principle) or a clearly erroneous factual finding, or (2) its decisionthough not necessarily the product of a legal error or a clearly erroneous factual findingcannot be located within the range of permissible decisions." Zervos v. Verizon N.Y., Inc., 252 F.3d 163, 169 (2d Cir. 2001) (footnotes omitted).

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