In People v. Jovanovic, 176 Misc 2d 729, 676 N.Y.S.2d 392 (Sup Ct New York County 1997), rev'd on other grounds, 263 AD2d 182, 700 N.Y.S.2d 156 (1st Dept 1999), the Court accepted and considered a motion and memorandum of law in support, submitted by counsel to the complainant, to oppose disclosure of the complainant's e-mails turned over to the court for in camera review by Columbia University in response to defendant's subpoena duces tecum. The Court noted that the complainant was not a party to the criminal action against Jovanovic, but held that, because she was affected by process of a court, she had standing to challenge the dissemination of e-mails between herself and third persons (id. at 731). In People v. Jovanovic, 176 Misc 2d 729, the court determined that disclosure pursuant to a subpoena duces tecum served by the defendant was inappropriate where he failed to make a clear and specific demonstration that third-party e-mails subpoenaed from the complainant's college e-mail account were highly material and relevant, were necessary or critical to his defense and that the information contained in the e-mails was not obtainable from other sources. On appeal from the judgment of conviction of kidnapping, assault, and sexual abuse, People v. Jovanovic, 263 A.D.2d 182, the appellate court reversed the defendant's convictions on the ground that the trial court improperly limited the use of certain evidence consisting of portions of e-mail communications between the defendant and the complainant.