Doe No. 1 v. Northwestern Memorial Hospital

Cryogenic tank at Defendant Hospital failed, causing loss of or damage to the semen and testicular tissue stored inside the tanks. All 40 Plaintiffs in pretrial discovery actions filed motions for leave to appear under fictitious names, per Section 2-401(e) of Code of Civil Procedure. Defendants were not entitled to notice of those motions, because they had not yet been named as parties to any suit initiated by Plaintiffs at time of motions. No waiver by any plaintiff of right to appear under fictitious name, because although Plaintiffs' counsel issued press release and held news conference, he actively protected Plaintiffs' identities throughout. (GORDON and REYES, concurring.)