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1.51 MB
Extraction Summary
3
People
2
Organizations
1
Locations
1
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing / motion (argument section)
File Size:
1.51 MB
Summary
This document is page 4 of a legal argument filed in a Florida court (evidenced by citations to Florida rules and case law) arguing to quash a subpoena. The filing argues that the Defendant's subpoena against 'Jane Doe No. 3' is abusive, oppressive, and unreasonable. It details that Jane Doe No. 3 was a minor victim of Jeffrey Epstein and that the Defendant is demanding sensitive materials such as her childhood diaries, photos of her as a minor, and cell phone records to further a campaign to jail the victim.
People (3)
| Name | Role | Context |
|---|---|---|
| Jane Doe No. 3 | Victim / Non-party |
Described as being sexually trafficked as a minor child by Jeffrey Epstein; target of the Defendant's subpoena.
|
| Jeffrey Epstein | Perpetrator |
Described as a convicted sex offender who sexually trafficked Jane Doe No. 3.
|
| Defendant | Defendant / Litigant |
Unnamed in this specific page, but described as issuing an 'abusive subpoena' and running a campaign to send Jane Doe...
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Florida Courts |
Implied by citation of Florida Rule of Civil Procedure and Florida District Court of Appeal cases.
|
|
| House Oversight Committee |
Implied by the Bates stamp 'HOUSE_OVERSIGHT'.
|
Timeline (1 events)
Past (minority of Jane Doe No. 3)
Locations (1)
| Location | Context |
|---|---|
|
Implied by legal citations (Fla. 2d DCA, Fla. 4th DCA).
|
Relationships (2)
Text states Jane Doe No. 3 was 'sexually trafficked as a minor child by Jeffrey Epstein'.
Defendant is issuing subpoenas to Jane Doe No. 3 and attempting to send her to jail.
Key Quotes (4)
"It is undisputed that Jane Doe No. 3 was sexually trafficked as a minor child by Jeffrey Epstein and he was sentenced for his crimes."Source
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Quote #1
"Allowing the Defendant in this case to force this non-party to provide discovery on this highly sensitive topic would be both oppressive and unreasonable"Source
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Quote #2
"...serves no purpose other than to foster Defendant’s publicly admitted and utterly baseless campaign to try to send Jane Doe No. 3 to 'jail.'"Source
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Quote #3
"Defendant... seeks highly personal and sensitive information from this victim of sexual trafficking, including requesting her personal diary during the time when she was being sexually abused as a minor child."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,162 characters)
ARGUMENT
1. This Court Should Quash Defendant’s Abusive Subpoena In Its Entirety.
Florida Rule of Civil Procedure 1.410(c)(1) provides that the Court may “quash or modify the subpoena if it is unreasonable and oppressive.” Id. The Court has discretion to evaluate the circumstances in determining whether the subpoena is “unreasonable and oppressive.” Matthews v. Kant, 427 So. 2d 369, 370 (Fla. 2d DCA 1983). “The sufficiency thereof is a factual determination for the trial judge who is vested with broad judicial discretion in the matter, and whose order will not be overturned absent a clear showing of abuse of discretion.” Id.; see also Sunrise Shopping Center, Inc. v. Allied Stores Corp., 270 So. 2d 32 (Fla. 4th DCA 1972) (Fourth DCA quashing lengthy subpoena served on non-party who was not in control of documents as being “oppressive and unreasonable.”). It is undisputed that Jane Doe No. 3 was sexually trafficked as a minor child by Jeffrey Epstein and he was sentenced for his crimes. Allowing the Defendant in this case to force this non-party to provide discovery on this highly sensitive topic would be both oppressive and unreasonable and serves no purpose other than to foster Defendant’s publicly admitted and utterly baseless campaign to try to send Jane Doe No. 3 to “jail.”
The documents requested in Defendant’s subpoena demonstrate the oppressive and unreasonable nature of the requests. Defendant, for example, seeks highly personal and sensitive information from this victim of sexual trafficking, including requesting her personal diary during the time when she was being sexually abused as a minor child. See Exhibit 6, Request no. 16. Defendant also demands that this non-party produce photographs and videos of her as a minor child while she was being sexually trafficked by convicted sex offender Jeffrey Epstein. See Exhibit 6, Request nos. 2, 3, 4 and 10. Defendant’s unreasonable subpoena even includes a demand for this non-party’s personal cell phone records for more than a three (3) year period during the time when she was a minor child being sexually trafficked. See Exhibit 6, Request no.
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HOUSE_OVERSIGHT_015602
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