Defendant threatens Jane Doe No. 3 with perjury prosecution and media campaign

result is that she'll go to jail because she will repeat her lies and we’ll be able to prove it and she will end up in prison for perjury.” (emphasis added). See Exhibit 1, New York Daily News, April 7, 2015. Defendant has subjected Jane Doe No. 3 to horrific public attacks including publicly calling her a “prostitute” and a “bad mother” to her three minor children. See Exhibit 2, Local 10 News, January 22, 2015. Defendant has gone on a media blitz campaign against this non-party for statements she made under oath in a federal action: “The end result of this case should be she [Jane Doe No. 3] should go to jail, the lawyers should be disbarred and everybody should understand that I am completely and totally innocent.” (emphasis added). See Exhibit 3, CNN International, New Day, January 6, 2015. “My goal is to bring charges against the client and require her to speak in court.” (emphasis added). See Exhibit 4, Australian Broadcasting System (ABC), January 6, 2015. Defendant also stated, in an interview in Newsmax, that he is “considering” bringing a lawsuit against Jane Doe No. 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.” (emphasis added). See Exhibit 5, Newsmax, April 8, 2015. Defendant’s own words demonstrate that he is abusing the subpoena power of this Court to try to get discovery that is irrelevant to this case, in the hopes of being able to intimidate Jane Doe No. 3 with the press and generate a claim against her. Considering the extensive abuse that Jane Doe No. 3 suffered as a minor child, and Defendant’s threats and intimidation, it would be both unreasonable and oppressive to require this non-party to comply with this subpoena duces tecum. Accordingly, Defendant’s subpoena should be quashed. See Exhibit 6, Defendant’s Subpoena to Jane Doe No. 3. HOUSE_OVERSIGHT_015600