When can a plaintiff proceed in a civil case under a pseudonym?

In cases where a party's request to proceed pseudonymously is based on a fear of retaliation, the district court should consider the following factors: (1) the severity of the threatened harm; (2) the reasonableness of the anonymous party's fears; and (3) the anonymous party's vulnerability to such retaliation. Id. at 1068; see also Doe, 655 F.2d at 922 n.1 (using pseudonyms for prison inmate appellant because he "faced a serious risk of bodily harm" if his role as a government witness were disclosed); Doe v. Madison School Dist. No. 321, 147 F.3d 832, 833 n.1 (9th Cir. 1998) (allowing plaintiff to proceed under a pseudonym because she feared retaliation from the community).