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rights of the non-party.”). Defendant has not established any basis for these privileged and confidential documents that outweighs this non-party’s privacy rights. 3. The Subpoena Should Be Quashed In Its Entirety. If the Court Will Not Take That Action, at a Minimum, It Should Grant a Protective Order Severely Limiting The Areas Of Inquiry At Deposition And Grant Protections For This Victim Who Is Fearful Of The Defendant. This Court has the power to preclude and/or limit the deposition of non-party Jane Doe No. 3. Specifically, Florida Rule of Civil Procedure 1.280(c) allows the Court to prevent a deposition from going forward “to protect a party or person from annoyance, embarrassment, oppression or undue burden or expense that justice requires,” and courts routinely enter protective orders to reduce the burden on subpoenaed non-parties to a case, as well as in cases where the discovery sough is irrelevant. See, e.g., Peisach v. Antuna, 539 So. 2d 544 (Fla. 3d DCA 1989) (holding that the trial judge erred in allowing the deposition of certain non-parties where evidence sought was irrelevant); see also Citimortgage, Inc. v. Davis, No. 50 2009 CA 030523, 2011 WL 3360318 (Fla. 15" Cir. Ct. April 4, 2011) (trial court granting protective order precluding a deposition noting “this deposition request is mere harassment” and had no relevance to the underlying dispute where the party was wrongfully using the discovery process for personal gain). Section 4 of Rule 1.280 provides that the Court can also limit the areas of inquiry of a deposition providing “that certain matters not be inquired into, or that the scope be limited to certain matters.” Jane Doe No. 3 contends that the subpoena for her deposition should be quashed. If the Court, however, is inclined to allow a deposition of Jane Doe No. 3, then she respectfully requests the issuance of a Protective Order modifying the subpoena as set forth below. a. Testimony Limitations Non-party Jane Doe No. 3 respectfully requests that this Court limit the deposition to questions directly related to Defendant’s defamatory statements about Brad Edwards and Paul Cassell. The Court should limit Defendant’s ability to engage in a “fishing expedition” of this 11 HOUSE_OVERSIGHT_015609