People v. Jovanovic

176 Misc. 2d 729, 676 N.Y.S.2d 392, 1997 N.Y. Misc. LEXIS 709
CourtNew York Supreme Court
DecidedSeptember 25, 1997
StatusPublished
Cited by3 cases

This text of 176 Misc. 2d 729 (People v. Jovanovic) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Jovanovic, 176 Misc. 2d 729, 676 N.Y.S.2d 392, 1997 N.Y. Misc. LEXIS 709 (N.Y. Super. Ct. 1997).

Opinion

[730]*730OPINION OF THE COURT

Budd G. Goodman, J.

The defendant has been indicted for the crimes of kidnapping, aggravated sexual abuse, sodomy and related crimes, arising out of an incident which occurred in November 1996. In connection therewith, the defendant subpoenaed from Columbia University copies of all e-mail communications sent to, and received by, the complainant, using her Columbia University e-mail account, between September and December 1996. Columbia University complied with the defendant’s subpoena duces tecum by producing directly to the court several computer disks, which when downloaded and printed consisted of some 2,400 written pages of communications between the complainant and the defendant and the complainant and various third parties. This court determined that it was appropriate for it to review the e-mails, in camera, in order to make a determination as to whether any or all of the materials produced should be disclosed to the defendant.

After reviewing the motion to oppose disclosure and memorandum of law in support thereof submitted by counsel to the complainant, a motion by the prosecution for a protective order preventing disclosure of the third-party e-mails and applicable statutory and case law, the court finds that the production by the court to the defendant of these third-party e-mails is not warranted, since the defendant has ultimately failed to establish (i) that the material sought pursuant to the subpoena duces tecum contains “evidence” (the defendant’s allegations in support thereof being merely speculative), and (ii) that he cannot obtain the information contained in the e-mails from other sources, i.e., speaking directly with the persons who communicated with the complainant in these e-mails. With regard to the latter, the court believes that the defendant has available to him sources of direct investigative access to the information sought by subpoena.

A subpoena duces tecum is a judicial subpoena returnable to the court. (Matter of Roman, 97 Misc 2d 782.) GPL 610.25 requires only the production to a court of materials subpoenaed, but it does not require the disclosure of such materials to the defense (or otherwise). (People v Harte, 99 Misc 2d 86.) It is a proper function for a court to conduct an in camera inspection of subpoenaed materials produced in order for the court to make a determination as to whether any of such material should be disclosed. (People v Chambers, 134 Misc 2d 688; [731]*731People v Miranda, 115 Misc 2d 533; People v Price, 100 Misc 2d 372; People v Harte, supra.) Where compelling social and policy considerations are confronted, a court has little choice but to expend the judicial time and effort necessary to make an in camera determination of whether the subpoenaed material should be disclosed, following such court’s in camera inspection. (People v Miranda, supra, at 536; Matter of Roman, supra, at 785; People v Simone, 92 Misc 2d 306, affd 71 AD2d 554 [1st Dept 1979].)

The court’s in camera examination of the third-party e-mails produced by Columbia University pursuant to the defendant’s subpoena found nothing in those materials to be directly relevant and material to the defendant’s case or which must or should be disclosed to the defendant.1 (See, People v Chambers, supra.) Any argument by the defendant that it is not the court’s role to make an in camera inspection or an ultimate determination as to the dissemination of the materials examined pursuant to the court’s in camera review, is without merit. (People v Chambers, supra; People v Miranda, supra; Matter of Roman, supra.)

Although the complainant is not a party to the criminal action against the defendant, any party affected by process of a court has standing to apply to the court for modification, vacatur or reconsideration of a decision or order issued by a court. (See, People v Grosunor, 108 Misc 2d 932.) Thus, the court finds that the complainant possesses standing to challenge the dissemination of the e-mails by and between herself and third parties.

The right of a defendant to compel a witness pursuant to a subpoena to give testimony or produce documentary or other physical evidence has a constitutional basis predicated upon a defendant’s need to compel the production of evidence in order to prepare and present a defense to the charges brought against him or her. (People v Morrison, 148 Misc 2d 61.) That right, however, rather than being an unlimited and unrestricted right to compel by compulsory process any documents sought by a [732]*732defendant, is a restricted right, whose exercise must satisfy certain relevancy and evidentiary standards and which is further subject to the availability of other means for obtaining the documents sought. (Supra.)

It has been held that “[t]he right to compel material pursuant to [a] subpoena is * * * limited to the compulsion of ‘evidence’ and is not a right to compel the production of documents that refer to evidence or that provide leads that will assist in the identification of evidence or to ascertain the existence of witnesses or evidence”. (People v Morrison, supra, at 67; accord, see, People v Di Lorenzo, 134 Misc 2d 1000; People v Simone, supra; People v Cammilleri, 123 Misc 2d 851; People v Chambers, supra; see, contra, People v Cabon, 148 Misc 2d 260.) With respect to the meaning of the term “evidence” (which should be distinguished from informational disclosure), CPL 610.10 (2) and (3) specifically provide that a subpoena is a process by which a person may be compelled to attend a court proceeding and appear as a witness (i.e., provide oral testimony) or appear and produce certain specified tangible evidence.2 New York courts have frequently held that a subpoena “may not be used for the purpose of discovery or to ascertain the existence of evidence”. (Matter of Terry D., 81 NY2d 1042, 1044 [1993]; People v Gissendanner, 48 NY2d 543, 551 [1979]; Matter of Constantine v Leto, 157 AD2d 376 [3d Dept 1990], affd 77 NY2d 975; People v Simone, 92 Misc 2d 306, affd 71 AD2d 554, supra; People v Bova, 118 Misc 2d 14; People v Di Lorenzo, supra; People v Cammilleri, supra; People v Morrison, supra.) A subpoena may also not be utilized to “fish for impeaching material.” (People v Hasson, 86 Misc 2d 781, 783; People v Price, 100 Misc 2d 372, supra; Matter of Roman, 97 Misc 2d 782, supra; People v Bova, supra [disclosure of materials denied where defendant claimed that the materials subpoenaed were relevant and material because they could shed light on a possible justification defense and might also provide a source of impeachment material against a key prosecution witness].) In order to benefit from the use of compulsory process a defendant must make a “clear and specific showing that the subpoenaed information is highly material and relevant, is necessary or [733]*733critical to the maintenance of his defense, and is not obtainable from other available sources.” (People v Bova, supra, at 22 [emphasis added]; People v Di Lorenzo, supra; People v Price, supra; Matter of Roman, supra; see also, United States v Iozia, 13 FED 335.) In connection therewith, a defendant’s offer of proof may not be predicated upon mere speculation (see, People v Baldwin,

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In re Lees
187 Misc. 2d 901 (New York Supreme Court, 2001)
People v. Bagley
183 Misc. 2d 523 (New York Supreme Court, 1999)
People v. Magliore
178 Misc. 2d 489 (Criminal Court of the City of New York, 1998)

Cite This Page — Counsel Stack

Bluebook (online)
176 Misc. 2d 729, 676 N.Y.S.2d 392, 1997 N.Y. Misc. LEXIS 709, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-jovanovic-nysupct-1997.