Filing # 33754151 E-Filed 10/27/2015 06:33:15 PM

Filing # 33754151 E-Filed 10/27/2015 06:33:15 PM IN THE CIRCUIT COURT OF THE 177" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION BRADLEY J. EDWARDS, and CASE NO. CACE 15-000072 PAUL G. CASSELL, Plaintiffs, Vv. ALAN DERSHOWITZ, Defendant. CONSOLIDATED REPLY IN SUPPORT OF NON-PARTY JANE DOE NO. 31 AND BOIES, SCHILLER & FLEXNER LLP’s MOTIONS TO QUASH OR FOR PROTECTIVE ORDERS REGARDING SUBPOENA SERVED ON THE NON-PARTIES Defendant served virtually identical subpoenas on non-party Giuffre, and her counsel Boies, Schiller & Flexner LLP (“BSF”). In an effort to conserve judicial resources, the non- parties are submitting a consolidated reply requesting that this Court quash the unreasonable and oppressive subpoenas pursuant to Florida Rules of Civil Procedure 1.410(c)(1), or alternatively, issue protective orders sharply limiting the scope of the abusive subpoenas pursuant to Florida Rules of Civil Procedure 1.280(c). INTRODUCTION After publicly stating that his main goal in seeking discovery from Giuffre is to put her in “jail”, Defendant served this non-party with a subpoena containing twenty five (25) unreasonable and oppressive requests. It is without question that Giuffre was sexually abused as ' Jane Doe No. 3 is Virginia Roberts Giuffre, and will hereinafter be referred to as “Guiuffre.” > See Exhibit 1, CNN International, New Day, January 6, 2015. See also Exhibit 2, Australian Broadcasting System (ABC), January 6, 2015. “My goal is to bring charges against the client and require her to speak in court.” 1 HOUSE_OVERSIGHT_010906