Proper way to allege a pseudonym in an indictment or information:

"Jane Doe"

or

"Jane Doe, a pseudonym"

or

either???????

I can't see why it would matter either way, but I've always seen it simply alleged as "Jane Doe." The only thing that matters, however you allege it, is making sure the defendant is notified in advance that "Jane Doe" is a pseudonym for [real name].

See Washington v. State, 59 S.W.3d 260 (Texarkana 2001), for some discussion.

Traditionally, we have said, Jane Doe, a pseudonym. However, I don't think it really matters as long as during testimony you explain that the girl testifying is the victim. I would make sure the defendant knows about whom you are speaking, but that is rarely a problem since it is his grandchild or some other relation.

A recent trial came up with a new problem where the defense attorney loudly called the child's father by name. The judge blew a gasket (since this effectively named the child in this small community). He cleared the courtroom except for the jury, and held the defense attorney in contempt, fining him $250 dollars. In a pre-trial hearing on the co-defendant, the defense attorney smirked and told the child victim that everyone knew who he was and so would it be allright to call him ****** (his real name). The child, to his credit, looked the attorney in the eye, and said, he should be called Jack Doe. It was a defining moment for my 10 year old victim. I knew we were going to do fine.

We use a number---pseudonym 083--and keep a list of who is given which number.