EFTA01078765Set 9
2015-04-0790p24,360w
party Jane Doe 3, by and through undersigned counsel and pursuant to Florida Rules
of Civil Procedure 1.410(c)(1)1, hereby moves for an order quashing the subpoena duces ... tecwn
served on her by Defendant, or alternatively, pursuant to Florida Rules of Civil Procedure 1.280(c)
for issuance of a protective order sharply limiting the scope of the subpoena ... allow Defendant to abuse the
subpoena power to further abuse this non-party. Florida Rules of Civil Procedure provide a
vehicle for this Court to protect a non-party from
https://www.justice.gov/epstein/files/DataSet%209/EFTA01078765.pdf
CASSELL,
Plaintiff,
vs.
ALAN M. DERSHOWITZ,
Defendant,
PROPOSAL FOR SETTLEMENT PURSUANT TO
RULE 1.442, FLORIDA RULES OF CIVIL PROCEDURE
AND 4768.79, FLORIDA STATUTES
Plaintiff, Paul G. Cassell, by and through ... trial, whichever is earlier.
THEREFORE, Plaintiff hereby serves this proposal for settlement pursuant to Florida
Rule of Civil Procedure 1.442 and F.S. 768.79. This proposal for settlement must be accepted
https://www.justice.gov/epstein/files/DataSet%209/EFTA00591859.pdf