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EFTA01206903

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Filing # 27349731 E-Filed 05/15/2015 01:43:57 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, v. ALAN M. DERSHOWITZ, Defendant / Counterclaim Plaintiff. DEFENDANT / COUNTERCLAIM PLAINTIFF ALAN DERSHOWITZ'S SUPPLEMENTAL MEMORANDUM IN SUPPORT OF HIS POSITION THAT JANE DOE NO. 3 MUST BE DEPOSED AND PRODUCE DOCUMENTS BEFORE HE IS DEPOSED OR REOUIRED TO PRODUCE REBUTTAL DOCUMENTS AS A MATTER OF DUE PROCESS AND FUNDAMENTAL FAIRNESS Defendant / Counterclaim Plaintiff Alan Dershowitz ("Dershowitz") respectfully submits this Supplemental Memorandum in support of his position that Jane Doe No. 3 must be deposed and produce documents before he is required to be deposed or to produce rebuttal documents, as a matter of fundamental fairness and due process.' This issue will be heard by the Court at the hearing set for June 5, 2015, pursuant to the Court's order of April 15, 2015 requiring additional argument regarding the timing and scope of discovery from Dershowitz. Jane Doe No. 3's motion to quash the deposition and document subpoena served on her is set for May 22, 2015, so As set forth in Dershowitz's memoranda in opposition to the motions to quash filed by non- parties Jane Doe No. 3 and Boies Schiller & Flexner, LLP, Jane Doe No. 3 has no right to proceed anonymously as she has been identified publicly on several occasions and has made public statements to the media using her own name. Nonetheless, Dershowitz will refer to her "Jane Doe No. 3" until the Court orders otherwise. EFTA01206903

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