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1.56 MB
Extraction Summary
3
People
3
Organizations
1
Locations
2
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal filing / motion (likely a motion for protective order or motion to quash subpoena)
File Size:
1.56 MB
Summary
This document is page 7 of a legal filing arguing against a subpoena issued by the Defendant to a non-party identified as 'Jane Doe 3.' The filing asserts that the Defendant is harassing the non-party by requesting irrelevant personal items like diaries and childhood photos from 1999-2002, a period when she was a minor victim of sex trafficking. It cites a Newsmax interview where the Defendant admitted to tracking the non-party to Colorado to serve her and expressed a desire to jail her.
People (3)
| Name | Role | Context |
|---|---|---|
| Defendant | Litigant |
Seeking discovery (diaries, photos) from a non-party; accused of using subpoena power to harass and intimidate.
|
| Jane Doe 3 | Non-party / Victim |
Described as a victim of sexual trafficking who was a minor during the relevant period (1999-2002); target of the Def...
|
| Non-party | Subject of Subpoena |
Refers to Jane Doe 3.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Newsmax |
Venue where the Defendant gave an interview threatening to sue the non-party.
|
|
| Fla. 3rd DCA |
Cited in legal precedent (Peisach v. Antuna).
|
|
| Fla. 15th Cir. Ct. |
Cited in legal precedent (Citimortgage, Inc. v. Davis).
|
Timeline (2 events)
January 1, 1999 - December 31, 2002
Locations (1)
| Location | Context |
|---|---|
|
Location where the Defendant claims Jane Doe 3 was 'trying to hide' to avoid service.
|
Relationships (1)
Defendant is issuing subpoenas against Jane Doe 3; Defendant expressed intent to sue her for defamation and put her in jail.
Key Quotes (5)
"Defendant is seeking personal diary information during the time this non-party was a minor child and a victim of sexual trafficking."Source
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Quote #1
"Photographs of Jane Doe 3 when she was a minor child are completely irrelevant to the matter before this Court."Source
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Quote #2
"Defendant served this subpoena demand solely to intimidate, harass and embarrass this non-party"Source
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Quote #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."Source
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Quote #4
"Defendant has admitted that his 'goal' is to put Jane Doe No. 3 in 'jail'"Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,266 characters)
January 1, 1999 and December 31, 2002.” Defendant is seeking personal diary information during
the time this non-party was a minor child and a victim of sexual trafficking. There is no reason
this non-party should be forced to produce her diary from when she was a child. See Peisach v.
Antuna, 539 So. 2d 544 (Fla. 3rd DCA 1989) (court of appeal holding that trial court departed
from the essential requirements of law by granting deposition of party’s gynecologist which was
only meant to invade privacy and intimidate and harass the party).
the time this non-party was a minor child and a victim of sexual trafficking. There is no reason
this non-party should be forced to produce her diary from when she was a child. See Peisach v.
Antuna, 539 So. 2d 544 (Fla. 3rd DCA 1989) (court of appeal holding that trial court departed
from the essential requirements of law by granting deposition of party’s gynecologist which was
only meant to invade privacy and intimidate and harass the party).
Defendant also has a number of requests (Request nos. 2, 3, 4, 10 and 19) that seek
“photographs” and “videos” of this non-party when she was a minor child and during the time she
was the subject of sexual abuse. Photographs of Jane Doe 3 when she was a minor child are
completely irrelevant to the matter before this Court. Defendant served this subpoena demand
solely to intimidate, harass and embarrass this non-party and the Court should preclude this type
of discovery set forth in Request Nos. 2, 3, 4, 10, 15, 16, 19 and 21. See Citimortgage, Inc. v.
Davis, No. 50 2009 CA 030523, 2011 WL 3360318 (Fla. 15th Cir. Ct. April 4, 2011) (trial court
granting protective order precluding a deposition noting “this deposition request is mere
harassment” and had no relevance to the underlying dispute where the party was wrongfully using
the discovery process for personal gain).
“photographs” and “videos” of this non-party when she was a minor child and during the time she
was the subject of sexual abuse. Photographs of Jane Doe 3 when she was a minor child are
completely irrelevant to the matter before this Court. Defendant served this subpoena demand
solely to intimidate, harass and embarrass this non-party and the Court should preclude this type
of discovery set forth in Request Nos. 2, 3, 4, 10, 15, 16, 19 and 21. See Citimortgage, Inc. v.
Davis, No. 50 2009 CA 030523, 2011 WL 3360318 (Fla. 15th Cir. Ct. April 4, 2011) (trial court
granting protective order precluding a deposition noting “this deposition request is mere
harassment” and had no relevance to the underlying dispute where the party was wrongfully using
the discovery process for personal gain).
b. Category 2 – Clear Abuse of the Subpoena Power By Seeking Documents Unrelated
to this Action and Intended Instead to Provide Discovery for Other Actions
to this Action and Intended Instead to Provide Discovery for Other Actions
Defendant is abusing the subpoena power of this Court by issuing subpoena requests that
are intended to obtain discovery for the development of other actions against this non-party and
are unrelated to the instant case. See Exhibit 5, Newsmax Interview (“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.”).
Defendant has admitted that his “goal” is to put Jane Doe No. 3 in “jail” and he is using this
Court’s subpoena power to go on a fishing expedition in the hopes of fulfilling his ultimate stated
are intended to obtain discovery for the development of other actions against this non-party and
are unrelated to the instant case. See Exhibit 5, Newsmax Interview (“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.”).
Defendant has admitted that his “goal” is to put Jane Doe No. 3 in “jail” and he is using this
Court’s subpoena power to go on a fishing expedition in the hopes of fulfilling his ultimate stated
7
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