An unnamed woman filed a complaint in Broward County against Howard on Oct. 26 alleging he knowingly and negligently gave her a sexually transmitted disease.
Through his attorney, Alan Mensa-Wilmot, Howard alleges that the plaintiff, listed as Jane Doe, threatened him, trespassed on his property, stalked him and spread false information about him.
Howard's motion, filed two days after the plaintiff's complaint, also states that he "has his own causes of action that he intends to bring against" Doe for her alleged "harassing tactics, defamatory statements, and intentional and/or negligent infliction of emotion distress."
The motion includes several screenshots of alleged text messages from the plaintiff, which Howard and his attorney say "make it abundantly clear that Plaintiff is nothing more than a scorned ex-lover" looking to obtain a financial windfall.
Mensa-Wilmot declined to comment on the ongoing case. Neither the Dolphins nor attorneys for Jane Doe could be reached for comment.
Howard's motion to dismiss states that he "has the right to compel Plaintiff to disclose her identity so that he may properly face his accuser in a court of law," and that the Plaintiff did not "satisfy the burden" she must meet in order to file using Jane Doe protection.
It continues to state that the Plaintiff must use her real name in all pleadings if she wishes to bring her complaint against Howard, and that failure to do so is grounds for dismissal. Howard's attorneys asked the court to impose their demand, which only a judge can do. Their motion cites prior cases in which plaintiffs alleging sexual assault were denied anonymity and that the case against Howard "describes an adult relationship of the type for which courts have traditionally denied anonymity."
Attorneys for the plaintiff, Bradley J. Edwards and Brittany N. Henderson, filed a motion on Oct. 31 to grant Jane Doe permission to continue anonymously. Their motion states that Jane Doe has sustained embarrassment, humiliation and psychological trauma that be "would greatly exacerbated if her name was revealed publicly." Her attorneys argue that because Howard already knows the identity of the plaintiff, she should be allowed to proceed anonymously.