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1.44 MB
Extraction Summary
4
People
3
Organizations
2
Locations
2
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal filing (motion background/argument)
File Size:
1.44 MB
Summary
This document is a background section of a legal motion filed by attorneys Paul Cassell and Brad Edwards in a defamation case. It argues that the Defendant (contextually Alan Dershowitz) is abusing subpoena power to harass a non-party victim, Jane Doe No. 3 (Virginia Giuffre), following a defamation campaign where the Defendant called the attorneys 'unethical' on the Today Show. The motion seeks to quash the subpoena to protect Jane Doe No. 3 from further intimidation.
People (4)
| Name | Role | Context |
|---|---|---|
| Paul Cassell | Plaintiff/Attorney |
Former federal judge representing sexual trafficking victims; filed defamation case against Defendant.
|
| Brad Edwards | Plaintiff/Attorney |
Colleague of Paul Cassell; filed defamation case against Defendant.
|
| Defendant | Defendant |
Unnamed in this specific page (contextually Alan Dershowitz); accused of defamation campaign and abusing subpoena pow...
|
| Jane Doe No. 3 | Non-party/Witness/Victim |
Sexual trafficking victim represented by Cassell/Edwards; subject of a subpoena the motion seeks to quash; fearful of...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Southern District of Florida |
Court where the CVRA case (08-cv-80736-KAM) is pending.
|
|
| Circuit Court of the Seventeenth Judicial Circuit for Broward County |
Court where the Florida Defamation Action (CACE 15-000072) was filed.
|
|
| Today Show |
Media outlet where Defendant allegedly made defamatory statements.
|
Timeline (2 events)
Unspecified
Filing of Florida Defamation Action (Case No. CACE 15-000072).
Broward County Circuit Court
Locations (2)
| Location | Context |
|---|---|
|
Jurisdiction for CVRA case.
|
|
|
Jurisdiction for Defamation Action.
|
Relationships (3)
referred to as 'his colleague Brad Edwards'
represent various sexual trafficking victims (context implies representation)
Jane Doe No. 3 has good cause to be fearful of the Defendant... based on Defendant’s repetitive threats.
Key Quotes (4)
"Defendant went on a national media defamation campaign calling, among other things, former federal judge Paul Cassell and attorney Brad Edwards, 'unethical lawyers' who should be 'disbarred'."Source
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Quote #1
"Defendant is determined to find a way to harm non-party Jane Doe No. 3 and anyone who braves to represent her."Source
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Quote #2
"Jane Doe No. 3 has good cause to be fearful of the Defendant in this matter based on Defendant’s repetitive threats."Source
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Quote #3
"Defendant’s campaign of threats and intimidation should not be condoned by this Court and Defendant’s subpoena should be quashed in its entirety."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,044 characters)
BACKGROUND
The underlying action before this Court is a defamation case filed by a former federal
judge, Paul Cassell, and his colleague Brad Edwards, who represent various sexual trafficking
victims in a case pending in the Southern District of Florida, specifically case no. 08-cv-80736-
KAM, hereinafter (“CVRA case”). As a result of an affidavit filed in the CVRA case, Defendant
went on a national media defamation campaign calling, among other things, former federal judge
Paul Cassell and attorney Brad Edwards, “unethical lawyers” who should be “disbarred”. See
Exhibit 7, Today Show, January 5, 2015. In response to this national slander campaign by the
Defendant, Paul Cassell and Brad Edwards filed a defamation case against Defendant in the
Circuit Court of the Seventeenth Judicial Circuit for Broward County, Case No. CACE 15-
000072, hereinafter “Florida Defamation Action”).
judge, Paul Cassell, and his colleague Brad Edwards, who represent various sexual trafficking
victims in a case pending in the Southern District of Florida, specifically case no. 08-cv-80736-
KAM, hereinafter (“CVRA case”). As a result of an affidavit filed in the CVRA case, Defendant
went on a national media defamation campaign calling, among other things, former federal judge
Paul Cassell and attorney Brad Edwards, “unethical lawyers” who should be “disbarred”. See
Exhibit 7, Today Show, January 5, 2015. In response to this national slander campaign by the
Defendant, Paul Cassell and Brad Edwards filed a defamation case against Defendant in the
Circuit Court of the Seventeenth Judicial Circuit for Broward County, Case No. CACE 15-
000072, hereinafter “Florida Defamation Action”).
Defendant’s statements against Paul Cassell and Brad Edwards are statements about their
character as lawyers and do not directly involve non-party Jane Doe No. 3. Despite this fact,
Defendant is abusing the subpoena power in this case by seeking documents from a non-party that
are irrelevant to the defamation issue before this Court. Defendant is determined to find a way to
harm non-party Jane Doe No. 3 and anyone who braves to represent her. Jane Doe No. 3 has good
cause to be fearful of the Defendant in this matter based on Defendant’s repetitive threats. See
Exhibit 8, Affidavit of Jane Doe No. 3. This Court should not allow Defendant to abuse the
subpoena power to further abuse this non-party. Florida Rules of Civil Procedure provide a
vehicle for this Court to protect a non-party from a harassing, burdensome and unnecessary
subpoena. As explained below, non-party Jane Doe No. 3 should be protected from having to be
deposed in this matter or produce documents. Defendant’s campaign of threats and intimidation
should not be condoned by this Court and Defendant’s subpoena should be quashed in its entirety.
character as lawyers and do not directly involve non-party Jane Doe No. 3. Despite this fact,
Defendant is abusing the subpoena power in this case by seeking documents from a non-party that
are irrelevant to the defamation issue before this Court. Defendant is determined to find a way to
harm non-party Jane Doe No. 3 and anyone who braves to represent her. Jane Doe No. 3 has good
cause to be fearful of the Defendant in this matter based on Defendant’s repetitive threats. See
Exhibit 8, Affidavit of Jane Doe No. 3. This Court should not allow Defendant to abuse the
subpoena power to further abuse this non-party. Florida Rules of Civil Procedure provide a
vehicle for this Court to protect a non-party from a harassing, burdensome and unnecessary
subpoena. As explained below, non-party Jane Doe No. 3 should be protected from having to be
deposed in this matter or produce documents. Defendant’s campaign of threats and intimidation
should not be condoned by this Court and Defendant’s subpoena should be quashed in its entirety.
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