Subpoena Demands Seek Evidence of Meetings with Bill Clinton, Al Gore, and Tipper Gore on Little Saint James Island

“goal.” See Toledo v. Publix Super Markets, Inc., 30 So. 3d 712 (Fla. 4" DCA 2010) (court of appeal quashing discovery order where party sought law firm client file relating to a different matter holding that “curiosity” about a law firm’s records does not satisfy the relevance requirement and explaining that the contents of the “subpoena is a classic ‘fishing expedition’ and the trial court’s order departs from the essential requirements of the law.”); Calvo v. Calvo, 489 So. 2d 833, 834 (Fla. 3d DCA 1986) (quashing subpoena served on wife’s bank for financial records finding them irrelevant: “indeed, the husband has failed to demonstrate what possible relevance the records might have in the proceeding below other than to harass the wife.’”). (emphasis added). Defendant’s incredibly broad and unrelated demands include, for example, Request no. 24: “All documents concerning, relating or referring to your assertions that you met former President Bill Clinton, Former Vice President Al Gore and/or Mary Elizabeth “Tipper” Gore on Little Saint James Island in the U.S. Virgin Islands.” See Exhibit 6, Request no. 24. Whether or not Jane Doe No. 3 met any of these individuals has absolutely nothing to do with the action before this Court. See Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 2003) (Florida Supreme Court holding that “we do not believe a litigant is entitled carte blanch to irrelevant discovery” and ““It is axiomatic that information sought in discovery must relate to the issues involved in the litigation, 999 as framed in the pleadings.’”) (internal citations omitted). Defendant’s Request demonstrates a blatant example of abuse of the subpoena power. Indeed, the face of many of Defendant’s subpoena demands demonstrate that he is using the subpoena power of this Court to obtain discovery for the federal action. Request nos. 1, 5, 6 and 9 all reference the “federal action” or specifically cite the declaration and case number “OS- SO736-CIV-MARRA/JOHNSON. Request no. 1, for example, demands: “All documents that reference by name, Alan M. Dershowitz, which support and/or confirm the allegations set forth in Paragraphs 24-31 of your Declaration dated January 19, 2015 and/or Paragraph 49 of your 8 HOUSE_OVERSIGHT_015606