Filing # 35983588 E-Filed 12/29/2015 03:18:34 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs/Counterclaim Defendants, vs. ALAN M. DERSHOWITZ, Defendant/Counterclaim Plaintiff. DEFENDANT ALAN M. DERSHOWITZ'S MOTION TO STAY FINANCIAL DISCOVERY Defendant Alan M. Dershowitz ("Dershowitz") respectfully moves this Court to issue a protective order to stay discovery of Dershowitz's personal finances purportedly relevant to the punitive damages claim asserted by Plaintiffs Bradley J. Edwards ("Edwards") and Paul G. Cassell ("Cassell") (together, "Plaintiffs"). The "net worth" and "punitive damages" discovery sought by Plaintiffs is not relevant to any liability issues in this defamation action. Moreover, such "net worth" and "punitive damages" discovery may well be mooted by dispositive motions. Even if such discovery is ultimately necessary, it can be quickly addressed after the Court rules on the sufficiency of Plaintiffs' punitive damages claim in connection with the parties' anticipated dispositive motions at the close of other fact discovery.' Requiring Dershowitz to respond to Plaintiffs' discovery now would be an enormous undertaking and would put Dershowitz's most sensitive personal financial information at risk of public disclosure, contrary To date, Plaintiffs have merely alleged in their pleading a claim for punitive damages. EFTA00593892