Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 25 of 34
i. failed to conduct any investigation of the allegations of Jane Doe #3 relating to you before referring to those allegations in a legal filing.
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.
21. Copies of any and all documents tending to support your assertion that Paul G. Cassell: 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;
i. failed to conduct any investigation of the allegations of Jane Doe #3 relating to you before referring to those allegations in a legal filing.
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.
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HOUSE_OVERSIGHT_014108