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Case File
d-18599House OversightDeposition

Motion to Quash Subpoena and Seek Protective Order for Non‑Party Jane Doe No. 3

The passage is a routine procedural filing seeking to limit a deposition of an anonymous non‑party. It contains no substantive allegations, financial flows, or connections to high‑ranking officials, a Jane Doe No. 3 is a non‑party resisting a subpoena for deposition. The motion cites Florida Rule of Civil Procedure 1.280(c) for protective orders. The request limits questioning to alleged defamator

Date
November 11, 2025
Source
House Oversight
Reference
House Oversight #015609
Pages
1
Persons
1
Integrity
No Hash Available

Summary

The passage is a routine procedural filing seeking to limit a deposition of an anonymous non‑party. It contains no substantive allegations, financial flows, or connections to high‑ranking officials, a Jane Doe No. 3 is a non‑party resisting a subpoena for deposition. The motion cites Florida Rule of Civil Procedure 1.280(c) for protective orders. The request limits questioning to alleged defamator

Persons Referenced (1)

Bradley Edwards

“...limit the deposition to questions directly related to Defendant’s defamatory statements about Brad Edwards and Paul Cassell. The Court should limit Defendant’s ability to engage in a “fishing expedition” o...”

Tags

protective-ordernonpartycivil-proceduredepositionlegal-exposurehouse-oversight
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Browse House Oversight Committee ReleasesHouse Oversight #015609

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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
rights of the non-party.”). Defendant has not established any basis for these privileged and confidential documents that outweighs this non-party’s privacy rights. 3. The Subpoena Should Be Quashed In Its Entirety. If the Court Will Not Take That Action, at a Minimum, It Should Grant a Protective Order Severely Limiting The Areas Of Inquiry At Deposition And Grant Protections For This Victim Who Is Fearful Of The Defendant. This Court has the power to preclude and/or limit the deposition of non-party Jane Doe No. 3. Specifically, Florida Rule of Civil Procedure 1.280(c) allows the Court to prevent a deposition from going forward “to protect a party or person from annoyance, embarrassment, oppression or undue burden or expense that justice requires,” and courts routinely enter protective orders to reduce the burden on subpoenaed non-parties to a case, as well as in cases where the discovery sough is irrelevant. See, e.g., Peisach v. Antuna, 539 So. 2d 544 (Fla. 3d DCA 1989) (holding that the trial judge erred in allowing the deposition of certain non-parties where evidence sought was irrelevant); see also Citimortgage, Inc. v. Davis, No. 50 2009 CA 030523, 2011 WL 3360318 (Fla. 15" Cir. Ct. April 4, 2011) (trial court granting protective order precluding a deposition noting “this deposition request is mere harassment” and had no relevance to the underlying dispute where the party was wrongfully using the discovery process for personal gain). Section 4 of Rule 1.280 provides that the Court can also limit the areas of inquiry of a deposition providing “that certain matters not be inquired into, or that the scope be limited to certain matters.” Jane Doe No. 3 contends that the subpoena for her deposition should be quashed. If the Court, however, is inclined to allow a deposition of Jane Doe No. 3, then she respectfully requests the issuance of a Protective Order modifying the subpoena as set forth below. a. Testimony Limitations Non-party Jane Doe No. 3 respectfully requests that this Court limit the deposition to questions directly related to Defendant’s defamatory statements about Brad Edwards and Paul Cassell. The Court should limit Defendant’s ability to engage in a “fishing expedition” of this 11

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Farmer, Jaffe, Weissing, Edwards, Fistos £t Lehrman, P.L. 'Ovid Pam ftoisl pet WWW.PATITTOJUSTKE.COM 425 North Andrews Avenue • Suite 2 Fort Lauderdale, Florida 33301 4 00 "ti e 6.‘ tk i r atire CalkAllfle alvdtr aIINNEV rar ,NYTTENNINIP PITNEY 'OWES 02 !F $003 , 50 0 000i3V, wit JAN 2i 2,2!3 .a4P En M ZIP t20-12E 3330 Dexter Lee A. Marie Villafatia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 EFTA00191396 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, 1. UNITED STATES, Respondent. SEALED DOCUMENT EFTA00191397 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, UNITED STATES, Respondent. SEALED DOCUMENT MOTION TO SEAL Petitioners Jane Doc No. 1 and Jane Doe No. 2, joined by movants Jane Doe No. 3 and Jane Doe No. 4, move to file the attached pleading and supporti

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Dershowitz’s Unproduced ‘Absolute Proof’ Documents and Media Claims in Epstein‑Related Defamation Litigation

The filing reveals that Alan Dershowitz repeatedly asserted on national TV that he possessed travel, credit‑card and other records proving he never met Jane Doe #3, yet has failed to produce any such Dershowitz claimed on Fox Business (Jan 7 2015) and CNN (Jan 5 2015) to have "all kinds of records" Despite a 45‑day deadline, he produced no documents and responded only with boilerplate objections

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Filing # 31897743 E-Filed 09/10/2015 12:44:35 PM

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EXHIBIT Q

EXHIBIT Q EFTA00097394 Case 1:15-cv-07433-RWS Document 189 Filed 06/06/16 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X INNIErt INIMINME, Plaintiff, v. GHISLATNE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RESPONSE IN OPPOSITION TO MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. EFTA00097395 Case 1:15-cv-07433-RWS Document 189 Filed 06/06/16 Page 2 of 11 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Response in Opposition to Plaintiff's Motion to Exceed Presumptive Ten Deposition Limit, and states as follows: INTRODUCTION Despite having taken only three depositions to date, Plaintiff prematurely requests permission to exceed the presumptive ten deposition limit imposed by Fed. R. Civ. P. 30(aX2)(A)(i) and to conduct 17 separate depositions, almost twice the limit. Without legal support, Plaintiff attempts to conflate the presumptive time limita

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