WILKINSON, Circuit Judge:
Plaintiffs brought suit under the pseudonyms Jane Doe and James Doe challenging the constitutionality of Virginia statutes prohibiting fornication and cohabitation. Va.Code §§ 18.2-344, 18.2-345 (1982). The district court granted both injunctive and declaratory relief on the grounds that these statutes violated plaintiffs' rights to privacy. Doe v. Duling,
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