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1.59 MB
Extraction Summary
4
People
3
Organizations
1
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal filing (motion to quash/objection to subpoena)
File Size:
1.59 MB
Summary
This is page 10 of a legal filing, specifically an objection to a subpoena in a Florida defamation action (likely related to Alan Dershowitz). 'Jane Doe No. 3' is arguing to quash requests for her personal financial information and privileged communications with her legal counsel, Boies, Schiller & Flexner LLP (BSF). The document cites Florida case law regarding attorney-client privilege and references specific discovery requests asking about her media interactions regarding Epstein, Dershowitz, and Prince Andrew.
People (4)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Subject of interest |
Mentioned in context of media statements regarding him
|
| Alan M. Dershowitz | Subject of interest/Litigant |
Mentioned in context of media statements; likely the Defendant in the 'Florida Defamation Action' mentioned
|
| Prince Andrew, Duke of York | Subject of interest |
Mentioned in context of media statements regarding him
|
| Jane Doe No. 3 | Non-party / Objector |
Individual objecting to subpoena requests regarding financial info and privileged communications
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Boies, Schiller & Flexner LLP (BSF) |
Law firm retained by Jane Doe No. 3; subject of discovery request no. 25
|
|
| Florida Courts |
Cited legal authority (4th DCA, 2nd DCA)
|
|
| House Oversight Committee |
Indicated by Bates stamp 'HOUSE_OVERSIGHT'
|
Timeline (1 events)
Locations (1)
| Location | Context |
|---|---|
|
Location of the 'Florida Defamation Action' and cited case law
|
Relationships (2)
Request no. 25 seeks documents concerning 'your retention of the law firm Boies, Schiller & Flexner LLP'
Document discusses statements regarding Epstein and 'being a sex slave'
Key Quotes (3)
"statements (whether 'on the record' or 'off the record') regarding Jeffrey Epstein, Alan M. Dershowitz, Prince Andrew, Duke of York, and/or being a sex slave."Source
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Quote #1
"Jane Doe No. 3, objects to all of Defendant’s subpoena requests to the extent that they seek documents protected by the attorney client privilege"Source
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Quote #2
"Request no. 25 seeks: 'All documents concerning your retention of the law firm Boies, Schiller & Flexner LLP...'"Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,352 characters)
media outlet in exchange for your statements (whether "on the record" or "off the record")
regarding Jeffrey Epstein, Alan M. Dershowitz, Prince Andrew, Duke of York, and/or being a sex
slave." Whether Jane Doe No. 3 has interacted with the media has nothing to do with the Florida
Defamation Action. As explained above, a non-party’s personal financial information and other
confidential information is subject to protection by this Court. See Woodward v. Berkery, 714 So.
2d 1027, 1034-38 (Fla. 4th DCA 1998). Accordingly, the requests relating to financial
information from this non-party should be quashed³.
regarding Jeffrey Epstein, Alan M. Dershowitz, Prince Andrew, Duke of York, and/or being a sex
slave." Whether Jane Doe No. 3 has interacted with the media has nothing to do with the Florida
Defamation Action. As explained above, a non-party’s personal financial information and other
confidential information is subject to protection by this Court. See Woodward v. Berkery, 714 So.
2d 1027, 1034-38 (Fla. 4th DCA 1998). Accordingly, the requests relating to financial
information from this non-party should be quashed³.
d. Category 4 – Plainly Privileged Communications
Defendant’s subpoena requests seek documents that are plainly privileged. Florida courts
are unequivocal in stating that an opposing party can never obtain attorney-client privileged
materials. See Quarles & Brady LLP v. Birdsall, 802 So. 2d 1205, 1206 (Fla. 2d DCA 2002)
(quashing discovery order and noting "undue hardship is not an exception (to disclosure of
privileged material), nor is disclosure permitted because the opposing party claims that the
privileged information is necessary to prove their case.") (internal citations omitted). Non-party,
Jane Doe No. 3, objects to all of Defendant’s subpoena requests to the extent that they seek
documents protected by the attorney client privilege, work product doctrine, joint defense and
common interest privileges and any other relevant privilege. Indeed, Jane Doe No. 3 should be
protected from responding to Request no. 25 in its entirety because on its face it seeks solely
privileged and confidential information relating to her retention of BSF.⁴ See Westco Inc. v. Scott
Lewis’ Gardening & Trimming, Inc., 26 So. 3d 620, 622 (Fla. 4th DCA 2010) (court explaining
that "[w]hen confidential information is sought from a non-party, the trial court must determine
whether the requesting party establishes a need for the information that outweighs the privacy
are unequivocal in stating that an opposing party can never obtain attorney-client privileged
materials. See Quarles & Brady LLP v. Birdsall, 802 So. 2d 1205, 1206 (Fla. 2d DCA 2002)
(quashing discovery order and noting "undue hardship is not an exception (to disclosure of
privileged material), nor is disclosure permitted because the opposing party claims that the
privileged information is necessary to prove their case.") (internal citations omitted). Non-party,
Jane Doe No. 3, objects to all of Defendant’s subpoena requests to the extent that they seek
documents protected by the attorney client privilege, work product doctrine, joint defense and
common interest privileges and any other relevant privilege. Indeed, Jane Doe No. 3 should be
protected from responding to Request no. 25 in its entirety because on its face it seeks solely
privileged and confidential information relating to her retention of BSF.⁴ See Westco Inc. v. Scott
Lewis’ Gardening & Trimming, Inc., 26 So. 3d 620, 622 (Fla. 4th DCA 2010) (court explaining
that "[w]hen confidential information is sought from a non-party, the trial court must determine
whether the requesting party establishes a need for the information that outweighs the privacy
³ These Requests include nos. 9, 17, 18, 20 and 23.
⁴ Specifically, Request no. 25 seeks: "All documents concerning your retention of the law firm Boies,
Schiller & Flexner LLP, including but not limited to: signed letter of retainer, retention agreement,
explanation of fees, and/or any documents describing the scope of retention."
⁴ Specifically, Request no. 25 seeks: "All documents concerning your retention of the law firm Boies,
Schiller & Flexner LLP, including but not limited to: signed letter of retainer, retention agreement,
explanation of fees, and/or any documents describing the scope of retention."
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