HOUSE_OVERSIGHT_015600.jpg
1.38 MB
Extraction Summary
3
People
6
Organizations
1
Locations
2
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal pleading / motion to quash subpoena
File Size:
1.38 MB
Summary
This document is page 2 of a legal filing arguing to quash a subpoena issued by the Defendant to 'Jane Doe No. 3' (a non-party witness/victim). The text details a 'media blitz' by the Defendant in early 2015, citing interviews with CNN, ABC, Newsmax, and the NY Daily News where the Defendant threatened Jane Doe No. 3 with jail for perjury, called her names, and stated intentions to sue her for defamation. The filing argues these actions constitute abuse of subpoena power and intimidation.
People (3)
| Name | Role | Context |
|---|---|---|
| Defendant | Defendant / Litigant |
Referred to as 'he'; accused of media blitz, intimidation, and abusing subpoena power against Jane Doe No. 3.
|
| Jane Doe No. 3 | Non-party / Victim / Witness |
Subject of the subpoena; accused by Defendant of lying; described as having suffered extensive abuse as a minor child.
|
| Minor Children | Family of Jane Doe No. 3 |
Mentioned in context of Defendant calling Jane Doe No. 3 a 'bad mother' to them.
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| New York Daily News |
Published statements by Defendant on April 7, 2015.
|
|
| Local 10 News |
Published report on January 22, 2015.
|
|
| CNN International |
aired 'New Day' interview with Defendant on January 6, 2015.
|
|
| Australian Broadcasting System (ABC) |
Aired interview with Defendant on January 6, 2015.
|
|
| Newsmax |
Conducted interview with Defendant on April 8, 2015.
|
|
| House Oversight Committee |
Indicated by the Bates stamp 'HOUSE_OVERSIGHT_015600'.
|
Timeline (2 events)
2015-01-22
Public attacks reported in Local 10 News calling Jane Doe No. 3 a 'prostitute' and 'bad mother'.
Media
2015-04-08
Defendant confirms finding and serving Jane Doe No. 3 in Colorado.
Colorado
Locations (1)
| Location | Context |
|---|---|
|
Location where Jane Doe No. 3 was allegedly 'trying to hide' and avoid service.
|
Relationships (1)
Defendant threatening jail, defamation suits, and issuing subpoenas against Jane Doe No. 3.
Key Quotes (5)
"result is that she’ll go to jail because she will repeat her lies and we’ll be able to prove it and she will end up in prison for perjury."Source
HOUSE_OVERSIGHT_015600.jpg
Quote #1
"publicly calling her a 'prostitute' and a 'bad mother' to her three minor children."Source
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Quote #2
"The end result of this case should be she [Jane Doe No. 3] should go to jail, the lawyers should be disbarred and everybody should understand that I am completely and totally innocent."Source
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Quote #3
"My goal is to bring charges against the client and require her to speak in court."Source
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Quote #4
"And we’re considering suing her for defamation as well, but right now she was trying to hide in Colorado and avoid service, but we found her and we served her and now she’ll be subjected to a deposition."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (1,978 characters)
result is that she’ll go to jail because she will repeat her lies and we’ll be able to prove it and she will end up in prison for perjury.” (emphasis added). See Exhibit 1, New York Daily News, April 7, 2015. Defendant has subjected Jane Doe No. 3 to horrific public attacks including publicly calling her a “prostitute” and a “bad mother” to her three minor children. See Exhibit 2, Local 10 News, January 22, 2015.
Defendant has gone on a media blitz campaign against this non-party for statements she made under oath in a federal action: “The end result of this case should be she [Jane Doe No. 3] should go to jail, the lawyers should be disbarred and everybody should understand that I am completely and totally innocent.” (emphasis added). See Exhibit 3, CNN International, New Day, January 6, 2015. “My goal is to bring charges against the client and require her to speak in court.” (emphasis added). See Exhibit 4, Australian Broadcasting System (ABC), January 6, 2015. Defendant also stated, in an interview in Newsmax, that he is “considering” bringing a lawsuit against Jane Doe No. 3. “And we’re considering suing her for defamation as well, but right now she was trying to hide in Colorado and avoid service, but we found her and we served her and now she’ll be subjected to a deposition.” (emphasis added). See Exhibit 5, Newsmax, April 8, 2015.
Defendant’s own words demonstrate that he is abusing the subpoena power of this Court to try to get discovery that is irrelevant to this case, in the hopes of being able to intimidate Jane Doe No. 3 with the press and generate a claim against her. Considering the extensive abuse that Jane Doe No. 3 suffered as a minor child, and Defendant’s threats and intimidation, it would be both unreasonable and oppressive to require this non-party to comply with this subpoena duces tecum. Accordingly, Defendant’s subpoena should be quashed. See Exhibit 6, Defendant’s Subpoena to Jane Doe No. 3.
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HOUSE_OVERSIGHT_015600
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