HOUSE_OVERSIGHT_015604.jpg
1.55 MB
Extraction Summary
4
People
2
Organizations
1
Locations
2
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal filing / motion (opposition to subpoena)
File Size:
1.55 MB
Summary
This document is page 6 of a legal filing arguing against a subpoena issued by the Defendant to a non-party identified as Jane Doe No. 3 in a Florida defamation case. The filing characterizes the subpoena as harassment intended to put the non-party in jail and notes that the Defendant specifically requested documents relating to Bill Clinton and Al Gore. The document argues these requests are irrelevant and violate Florida Rules of Civil Procedure.
People (4)
| Name | Role | Context |
|---|---|---|
| Jane Doe No. 3 | Non-party |
Subject of a subpoena; filing objections to document requests.
|
| Defendant | Litigant |
Issued the subpoena; allegedly stated a goal to put Jane Doe No. 3 in jail.
|
| Bill Clinton | Former President |
Named in the subpoena request; Defendant sought documents relating to him.
|
| Al Gore | Former Vice President |
Named in the subpoena request; Defendant sought documents relating to him.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Florida District Court of Appeal (4th DCA) |
Referenced in case citation.
|
|
| House Oversight Committee |
Referenced in Bates stamp (HOUSE_OVERSIGHT_015604).
|
Timeline (2 events)
Locations (1)
| Location | Context |
|---|---|
|
Location of the 'Florida Defamation Action'.
|
Relationships (3)
Defendant issued subpoena; stated goal to put Jane Doe No. 3 in jail.
Defendant sought documents relating to Clinton from Jane Doe No. 3.
Defendant sought documents relating to Gore from Jane Doe No. 3.
Key Quotes (4)
"Defendant issued a vastly overbroad subpoena to this non-party which included 25 separate document requests"Source
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Quote #1
"seek documents relating to former President, Bill Clinton and former Vice President, Al Gore"Source
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Quote #2
"Defendant’s admitted 'goal' of putting this non-party in 'jail,'"Source
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Quote #3
"Request no. 16 seeks 'Any diary, journal or calendar concerning your activities between"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,247 characters)
not be had” or that “the discovery may be had only on specified terms and conditions…”. Fla. R.
Civ. P. 1.280(c).
Civ. P. 1.280(c).
Defendant issued a vastly overbroad subpoena to this non-party which included 25
separate document requests, many with subparts. In addition to placing an undue burden on this
non-party to have to search for the broad scope of materials requested, the document requests seek
information that is irrelevant to the Florida Defamation Action and clearly intended to “embarrass
and oppress” this non-party. Fla. R. Civ. P. 1.280(c). Defendant’s overly broad subpoena to non-
party, Jane Doe No. 3, goes so far as to seek documents relating to former President, Bill Clinton
and former Vice President, Al Gore, which, even if such documents existed, would be absolutely
irrelevant to the Florida Defamation Action. See Toledo v. Publix Super Markets, Inc., 30 So. 3d
712 (Fla. 4th DCA 2010).
separate document requests, many with subparts. In addition to placing an undue burden on this
non-party to have to search for the broad scope of materials requested, the document requests seek
information that is irrelevant to the Florida Defamation Action and clearly intended to “embarrass
and oppress” this non-party. Fla. R. Civ. P. 1.280(c). Defendant’s overly broad subpoena to non-
party, Jane Doe No. 3, goes so far as to seek documents relating to former President, Bill Clinton
and former Vice President, Al Gore, which, even if such documents existed, would be absolutely
irrelevant to the Florida Defamation Action. See Toledo v. Publix Super Markets, Inc., 30 So. 3d
712 (Fla. 4th DCA 2010).
Defendant’s requests can be grouped into four key categories: (1) documents that contain
highly personal and sensitive information sought only to harass, embarrass and intimidate the non-
party; (2) documents unrelated to this action and, instead, intended to gain discovery relating to
Defendant’s admitted “goal” of putting this non-party in “jail,” bringing a new case against Jane
Doe No. 3, or related to the federal action; (3) documents that contain personal financial or other
confidential information; and (4) privileged communications between the non-party and her
lawyers. Non-party, Jane Doe No. 3, has filed specific objections as to each request sought in
Defendant’s subpoena as set forth in Exhibit 9. Here, Jane Doe No. 3 provides the Court with a
sampling of the oppressive nature of the subpoena that is the subject of her detailed objections.
highly personal and sensitive information sought only to harass, embarrass and intimidate the non-
party; (2) documents unrelated to this action and, instead, intended to gain discovery relating to
Defendant’s admitted “goal” of putting this non-party in “jail,” bringing a new case against Jane
Doe No. 3, or related to the federal action; (3) documents that contain personal financial or other
confidential information; and (4) privileged communications between the non-party and her
lawyers. Non-party, Jane Doe No. 3, has filed specific objections as to each request sought in
Defendant’s subpoena as set forth in Exhibit 9. Here, Jane Doe No. 3 provides the Court with a
sampling of the oppressive nature of the subpoena that is the subject of her detailed objections.
a. Category 1 – Overly Broad Subpoena Requests Intended Solely to Harass, Embarrass
and Intimidate the Non-Party by Seeking Highly Personal and Sensitive Information
and Intimidate the Non-Party by Seeking Highly Personal and Sensitive Information
It is clear from the Defendant’s requests that his intent is to intimidate and harass this non-
party by seeking highly sensitive personal information that is irrelevant to this action. For
example, Request no. 16 seeks “Any diary, journal or calendar concerning your activities between
party by seeking highly sensitive personal information that is irrelevant to this action. For
example, Request no. 16 seeks “Any diary, journal or calendar concerning your activities between
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HOUSE_OVERSIGHT_015604
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