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to be "well-founded." For example, Jane Doe No. 3 has made statements to the media about meeting former President Clinton and former Vice President Gore on Epstein's private island in the Caribbean. [ADD SENTENCE ON THIS:4a'so goes to what Cassell and Edwards knew or should have known when they file
bout meeting former President Clinton and former Vice President Gore on Epstein's private island in the Caribbean. [AD
ment are inapposite because they involved attempts to obtain information that had no "possible relevance" to the issues in dispute. For example, in Calvo v. Calvo, 489 So. 2d 833, 834 (Fla. 3d DCA 1986), the Third District held that an ex-wife's financial records had no "possible relevance" to her po
bout meeting former President Clinton and former Vice President Gore on Epstein's private island in the Caribbean. De
to be "well-founded." For example, Jane Doe No. 3 has made statements to the media about meeting former President Clinton and former Vice President Gore on Epstein's private island in the Caribbean. Dershowitz is entitled to explore the veracity of Jane Doe No. 3's accounts of these meetings, becaus
ment are inapposite because they involved attempts to obtain information that had no "possible relevance" to the issues in dispute. For example, in Calvo v. Calvo, 489 So. 2d 833, 834 (Fla. 3d DCA 1986), the Third District held that an ex-wife's financial records had no "possible relevance" to her po
broad subpoena to non- party, Jane Doe No. 3, goes so far as to seek documents relating to former President, Bill Clinton and former Vice President, Al Gore, which, even if such documents existed, would be absolutely irrelevant to the Florida Defamation Action. See Toledo v. Publix Super Markets, Inc., 30
Page: HOUSE_OVERSIGHT_015604 →ident, Bill Clinton and former Vice President, Al Gore, which, even if such documents existed, would be
Page: HOUSE_OVERSIGHT_015604 →at 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
Page: HOUSE_OVERSIGHT_015606 →first offender . . . [because] repeated misconduct is more reprehensible than an individual instance of malfeasance.” BMW of North America, Inc. Vv. Gore, 517 U.S. 559, 577 (1996) (supporting citations omitted). In addition, juries can consider other similar acts evidence as part of the deterrence calc
Page: HOUSE_OVERSIGHT_013386 →ntiary hearing is not required. See Strasser v. Yalmanchi, 677 So.2d 22, 23 (Fla. 4th DCA 1996), rev. dismissed, 699 So.2d 1372 (Fla. 1997); Solis v. Calvo, 689 So.2d 366, 369, n.2 (Fla. 3d DCA 1997). In fact, a hearing is not even required provided the trial court identifies the filings of the parties a
Page: HOUSE_OVERSIGHT_013397 →Entities connected to both Al Gore and Calvo

Jeffrey Epstein
PERSON
Bill Clinton
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
United States
LOCATION
Virginia Giuffre
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSON
Vicky Ward
PERSONMartin Weinberg
PERSON
David Boies
PERSONJane Doe
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
U.S. Virgin Islands
LOCATION
Colorado
LOCATIONJack Scarola
PERSONSigrid McCawley
PERSON