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1.57 MB
Extraction Summary
6
People
3
Organizations
1
Locations
2
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal filing / motion (opposition to subpoena/discovery)
File Size:
1.57 MB
Summary
This document is page 8 of a legal filing arguing against a Defendant's subpoena requests, characterizing them as a 'fishing expedition' and an abuse of power. The text specifically highlights 'Request no. 24,' which sought documents regarding Jane Doe No. 3's assertions that she met Bill Clinton, Al Gore, and Tipper Gore on Little Saint James Island. The filing argues these requests are irrelevant to the current court action and are being used to gather discovery for a separate federal case (Case No. 0S-SO736-CIV-MARRA/JOHNSON) involving Alan Dershowitz.
People (6)
| Name | Role | Context |
|---|---|---|
| Bill Clinton | Former President |
Subject of a discovery request (Request no. 24) asking for documents regarding an alleged meeting with Jane Doe No. 3...
|
| Al Gore | Former Vice President |
Subject of a discovery request (Request no. 24) asking for documents regarding an alleged meeting with Jane Doe No. 3...
|
| Mary Elizabeth "Tipper" Gore | Al Gore's wife |
Subject of a discovery request (Request no. 24) asking for documents regarding an alleged meeting with Jane Doe No. 3...
|
| Jane Doe No. 3 | Plaintiff/Witness |
The individual subject to the subpoena requests; the filing argues whether she met the politicians is irrelevant to t...
|
| Alan M. Dershowitz | Defendant (implied context) |
Named in Request no. 1; the filing suggests the Defendant is using this court's power to get discovery for a federal ...
|
| Defendant | Litigant |
The party issuing the 'broad and unrelated' subpoena demands.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Publix Super Markets, Inc. |
Cited in case law (Toledo v. Publix Super Markets, Inc.).
|
|
| Allstate Ins. Co. |
Cited in case law (Allstate Ins. Co. v. Langston).
|
|
| Florida Supreme Court |
Court authority cited in legal argument.
|
Timeline (2 events)
January 19, 2015
Date of a Declaration referenced in Request no. 1.
Federal Court (implied)
Unknown
Alleged meeting between Jane Doe No. 3, Bill Clinton, and Al Gore (disputed relevance).
Little Saint James Island, U.S. Virgin Islands
Locations (1)
| Location | Context |
|---|---|
|
Location where Jane Doe No. 3 allegedly met Clinton and the Gores, according to the assertions being probed by the su...
|
Relationships (3)
Discovery request seeks documents regarding assertions that they met on Little Saint James.
Discovery request seeks documents regarding assertions that they met on Little Saint James.
Request no. 1 seeks documents referencing Dershowitz supporting allegations in Jane Doe's declaration.
Key Quotes (4)
"Defendant’s incredibly broad and unrelated demands include, for example, Request no. 24: “All documents concerning, relating or referring to your assertions that you met former President Bill Clinton, Former Vice President Al Gore and/or Mary Elizabeth “Tipper” Gore on Little Saint James Island in the U.S. Virgin Islands.”"Source
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Quote #1
"Whether or not Jane Doe No. 3 met any of these individuals has absolutely nothing to do with the action before this Court."Source
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Quote #2
"Defendant’s Request demonstrates a blatant example of abuse of the subpoena power."Source
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Quote #3
"Request nos. 1, 5, 6 and 9 all reference the “federal action” or specifically cite the declaration and case number “0S-SO736-CIV-MARRA/JOHNSON."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,267 characters)
“goal.” See Toledo v. Publix Super Markets, Inc., 30 So. 3d 712 (Fla. 4th DCA 2010) (court of
appeal quashing discovery order where party sought law firm client file relating to a different
matter holding that “curiosity” about a law firm’s records does not satisfy the relevance
requirement and explaining that the contents of the “subpoena is a classic ‘fishing expedition’ and
the trial court’s order departs from the essential requirements of the law.”); Calvo v. Calvo, 489
So. 2d 833, 834 (Fla. 3d DCA 1986) (quashing subpoena served on wife’s bank for financial
records finding them irrelevant: “indeed, the husband has failed to demonstrate what possible
relevance the records might have in the proceeding below other than to harass the wife.”).
(emphasis added).
appeal quashing discovery order where party sought law firm client file relating to a different
matter holding that “curiosity” about a law firm’s records does not satisfy the relevance
requirement and explaining that the contents of the “subpoena is a classic ‘fishing expedition’ and
the trial court’s order departs from the essential requirements of the law.”); Calvo v. Calvo, 489
So. 2d 833, 834 (Fla. 3d DCA 1986) (quashing subpoena served on wife’s bank for financial
records finding them irrelevant: “indeed, the husband has failed to demonstrate what possible
relevance the records might have in the proceeding below other than to harass the wife.”).
(emphasis added).
Defendant’s incredibly broad and unrelated demands include, for example, Request no. 24:
“All documents concerning, relating or referring to your assertions that you met former President
Bill Clinton, Former Vice President Al Gore and/or Mary Elizabeth “Tipper” Gore on Little Saint
James Island in the U.S. Virgin Islands.” See Exhibit 6, Request no. 24. Whether or not Jane Doe
No. 3 met any of these individuals has absolutely nothing to do with the action before this Court.
See Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 2003) (Florida Supreme Court holding
that “we do not believe a litigant is entitled carte blanch to irrelevant discovery” and “‘It is
axiomatic that information sought in discovery must relate to the issues involved in the litigation,
as framed in the pleadings.’”) (internal citations omitted). Defendant’s Request demonstrates a
blatant example of abuse of the subpoena power.
“All documents concerning, relating or referring to your assertions that you met former President
Bill Clinton, Former Vice President Al Gore and/or Mary Elizabeth “Tipper” Gore on Little Saint
James Island in the U.S. Virgin Islands.” See Exhibit 6, Request no. 24. Whether or not Jane Doe
No. 3 met any of these individuals has absolutely nothing to do with the action before this Court.
See Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 2003) (Florida Supreme Court holding
that “we do not believe a litigant is entitled carte blanch to irrelevant discovery” and “‘It is
axiomatic that information sought in discovery must relate to the issues involved in the litigation,
as framed in the pleadings.’”) (internal citations omitted). Defendant’s Request demonstrates a
blatant example of abuse of the subpoena power.
Indeed, the face of many of Defendant’s subpoena demands demonstrate that he is using
the subpoena power of this Court to obtain discovery for the federal action. Request nos. 1, 5, 6
and 9 all reference the “federal action” or specifically cite the declaration and case number “0S-
SO736-CIV-MARRA/JOHNSON. Request no. 1, for example, demands: “All documents that
reference by name, Alan M. Dershowitz, which support and/or confirm the allegations set forth in
Paragraphs 24-31 of your Declaration dated January 19, 2015 and/or Paragraph 49 of your
the subpoena power of this Court to obtain discovery for the federal action. Request nos. 1, 5, 6
and 9 all reference the “federal action” or specifically cite the declaration and case number “0S-
SO736-CIV-MARRA/JOHNSON. Request no. 1, for example, demands: “All documents that
reference by name, Alan M. Dershowitz, which support and/or confirm the allegations set forth in
Paragraphs 24-31 of your Declaration dated January 19, 2015 and/or Paragraph 49 of your
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