Document requests in case 9:08-cv-80736-KAM seek evidence of alleged prostitution and misconduct by Jane Doe #3 and attorney Bradley J. Edwards

Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 24 of 34 18. | Copies of any and all documents reflecting that Jane Doe #3 has ever willfully engaged in prostitution. RESPONSE: Defendant objects to this Document Request as vague because Defendant is not in a position to determine the willful nature of Jane Doe #3’s prostitution. Defendant further objects to this Document Request because Jane Doe #3 has repeatedly and publicly asserted that she gave her body for sexual activity for hire after the age of 18 and agreed to secure other persons for the purpose of prostitution or for any other lewd or indecent act and therefore the Document Request is unduly burdensome. 19. Copies of any and all documents reflecting that Jane Doe #3 is either a liar or has perjured herself in any way. 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. 20. Copies of any and all documents tending to support your assertion that Bradley J. Edwards: a. has a reputation of being sleazy; b. has acted in a sleazy manner; c. has engaged in unethical conduct; d. has knowingly relied upon false statements in any legal document filed by him; e. has engaged in any form of unethical conduct; f. has engaged in any form of conduct tending to demonstrate a lack of fitness to engage in the practice of law; g. has engaged in any form of conduct warranting the loss of his license to practice law or the imposition of any professional disciplinary action against him; h. has acted in a corrupt manner; HOUSE_OVERSIGHT_014107