HOUSE_OVERSIGHT_014101.jpg
1.57 MB
Extraction Summary
3
People
2
Organizations
1
Locations
1
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal pleading (response to request for production of documents)
File Size:
1.57 MB
Summary
This document is a page from a legal filing (Case 9:08-cv-80736-KAM) originating from the Southern District of Florida, dated March 24, 2015. It contains the Defendant's legal objections to document requests regarding IT systems and metadata. Crucially, it includes a response to a request for documents regarding visits to Little Saint James Island; the Defendant agrees to produce documents relating to the 'sole occasion' they were physically present on the island, a visit referenced in a sworn declaration by Alan Dershowitz.
People (3)
| Name | Role | Context |
|---|---|---|
| Defendant | Respondent |
The party responding to the legal requests; admits to being present on Little Saint James Island on one sole occasion.
|
| Alan M. Dershowitz | Declarant |
Mentioned as having provided a sworn declaration (specifically paragraph 3) describing the Defendant's visit to Littl...
|
| Plaintiffs | Opposing Party |
Mentioned in the context of document possession.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| FLSD |
Southern District of Florida (Court Docket)
|
|
| House Oversight Committee |
Indicated by the footer stamp 'HOUSE_OVERSIGHT_014101'
|
Locations (1)
| Location | Context |
|---|---|
|
The location the Defendant is being questioned about visiting.
|
Relationships (2)
Defendant admits to a 'sole occasion on which Defendant was physically present on Little Saint James Island.'
Dershowitz's sworn declaration describes the Defendant's visit to the island.
Key Quotes (2)
"Defendant responds that he will produce all responsive, non-privileged documents currently in his possession, custody or control relating to the sole occasion on which Defendant was physically present on Little Saint James Island."Source
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Quote #1
"Copies of any and all documents reflecting or relating to any and all occasions on which you have been physically present on Little Saint James Island including but not limited to your visit to Little Saint James Island, as described in paragraph 3 of the sworn Declaration of Alan M. Dershowitz."Source
HOUSE_OVERSIGHT_014101.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (1,765 characters)
Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 18 of 34
Defendant’s possession, custody, or control; is publicly available; is already in Plaintiffs’
possession, care, custody, or control; or is generally available to Plaintiffs.
possession, care, custody, or control; or is generally available to Plaintiffs.
6. Defendant generally objects to the Document Requests to the extent that the
information sought is not identified with sufficient particularity.
information sought is not identified with sufficient particularity.
7. Defendant objects to the definition of “Documents” to the extent that it seeks the
production of things beyond the scope of Rule 1.280 of the Florida Rules of Civil Procedure.
Defendant further objects to the definition of “Documents” to the extent that it seeks “electronic
data as well as application metadata and system metadata” and “inventories and rosters of your
information technology (IT) systems – e.g., hardware, software and data, including but not
limited to network drawings, lists of computing devices (servicers, PCs, laptops, PDAs, cell
phones, with data storage and/or transmission features), programs, data maps and security tools
and protocols” as overly broad and unduly burdensome.
production of things beyond the scope of Rule 1.280 of the Florida Rules of Civil Procedure.
Defendant further objects to the definition of “Documents” to the extent that it seeks “electronic
data as well as application metadata and system metadata” and “inventories and rosters of your
information technology (IT) systems – e.g., hardware, software and data, including but not
limited to network drawings, lists of computing devices (servicers, PCs, laptops, PDAs, cell
phones, with data storage and/or transmission features), programs, data maps and security tools
and protocols” as overly broad and unduly burdensome.
RESPONSES TO REQUESTS
1. Copies of any and all documents reflecting or relating to any and all occasions on which
you have been physically present on Little Saint James Island including but not limited to your
visit to Little Saint James Island, as described in paragraph 3 of the sworn Declaration of Alan
M. Dershowitz.
you have been physically present on Little Saint James Island including but not limited to your
visit to Little Saint James Island, as described in paragraph 3 of the sworn Declaration of Alan
M. Dershowitz.
RESPONSE:
Subject to and without waiving the General Objections, Defendant responds that he will produce
all responsive, non-privileged documents currently in his possession, custody or control relating
to the sole occasion on which Defendant was physically present on Little Saint James Island.
all responsive, non-privileged documents currently in his possession, custody or control relating
to the sole occasion on which Defendant was physically present on Little Saint James Island.
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HOUSE_OVERSIGHT_014101
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