In his PROPOSED Order doctor Tameira Hollander’s attorney Irving Johnson wrote:
2. Ms. Baker has admitted she has no evidence to connect “Matthew Hilton” to Dr. Hollander, and Dr. Hollander has testified she does not know “Matthew Hilton” and he is not an agent of hers, and the Court therefore finds that “Matthew Hilton” is not Dr. Hollander’s agent for any purposes which might be pertinent to this matter.
Of course I have PLENTY of evidence to connect “Mathew Hilton” to doctor Hollander’s ATTORNEY!
Mr. Johnson,
Doctor Hollander testified at one of the hearings under oath that she does not know the person who identified himself as “Mathew Hilton” and viciously harassed, abused and threatened me.
As you know, he sent me the pictures taken by your process server.
As you previously admitted, you have been in contact with other subjects of my publications and since “Mathew Hilton” also knew that you were going to file your contempt motion, he obviously received information and the pictures from you or doctor Hollander or someone else with access to your litigation strategy and the pictures.
Notably, the attacks stopped shortly after my 1/19/09 request.
Please identify all persons who received the pictures the process server took on my property from you or from anyone else in your office.
Christine Baker
I will update with his response.
I decided to post some discovery questions and documents to request. Whether I have an attorney or not, discovery ought to be submitted ASAP to get to the bottom of this harassment suit.
Of course there are MANY more questions and docs, but below are some of the things I’ve thought about.
Requests for Admissions:
- You admit that you submitted your demand to remove all references to http://tameirahollandermd.com to Ms. Baker on 8/9/08. [Exh. 1 -- see the factual summary]
- You admit that you submitted your demand to Ms. Baker anonymously. [Exh. 1]
- You admit that you failed to provide a valid email address with your demand. [Exh. 1]
- You admit that you failed to provide any contact information with your demand. [Exh. 1]
- You admit that you viewed at Ms. Baker’s blog her public request for identification of specific allegedly libelous information.
- You admit that you never identified any allegedly libelous statement to Ms. Baker.
- You admit that you never provided a link to a web page containing allegedly libelous information to Ms. Baker.
- You admit that your 8/9/08 form submisstion [Exh. 1] was your only communication with Ms. Baker.
- You admit that Ms. Baker never linked to http://tameirahollandermd.com.
Interrogatories:
- Description of all allegedly libelous information at Ms. Baker’s websites.
- Description of damages
- All communications to Ms. Baker.
- All communications with the Baileys.
- All communications with others who published allegedly libelous information
- Number of books sold to date
- Number of patients lost due to the Baileys’ publications
- Number of patients lost due to Ms. Baker’s publications
- Hours NOT worked because of lack of patients (I hear so many complaints about weeks and MONTHS of waits for doctor appointments. It sure is odd to see a doctor NOT overbooked)
Requests for Production of Documents:
- All documents consulted to answer Requests for Admissions and Interrogatories.
- All documents containing allegedly libelous information published by the Baileys, Ms. Baker and others.
- The Baileys’ complaint to the med board and their response.
- Tax returns from 2005 – present
I have never been involved in any kind of free speech case, so these are just a few discovery requests I’ve been thinking of.
If you have any discovery samples for a similar case, please post or send them to me.
